Tori Roessler

Senior Counsel

Tori Roessler focuses her practice on federal and state tax issues arising in representing financial institutions, developers, utilities, and other participants in energy, project finance, and leveraged lease transactions. Tori routinely advises clients on renewable energy projects, including solar, wind, and storage projects. She is familiar with current tax equity structures in use in the market, with an emphasis on partnership flip and inverted lease transactions, and advises on utility, commercial, and residential projects.

Tori is familiar with various federal and state tax incentives, including the investment tax credit (ITC) and production tax credit (PTC) and tax incentives related to energy transition projects and investments, such as Section 45Q carbon capture and sequestration credits. Additionally, she regularly helps clients qualify for such federal tax incentives and implement transaction structures that maximize the value of those incentives.

Tori routinely advises clients on the significant changes brought about under the Inflation Reduction Act, including the satisfying start of construction requirements, and obtaining new additional tax credits for satisfying domestic content requirements or locating renewable energy projects in energy or low-income communities. She also is well-versed in the rules and regulations surrounding transferability and direct pay options for renewable energy tax credits, as provided in the Inflation Reduction Act.

Presentations and Publications

  • Presenter, “Beginning Construction for Section 45Q Tax Credits,” Infocast CCS/Decarbonization, Project Development, Finance & Investment Summit (July 24, 2023)
  • Speaker, “Qualifying Beginning of Construction Section 45Q Tax Credits,” Infocast CCS/Decarbonization Project Development, Finance & Investment Summit (July 2023)
  • Speaker, Green Energy Law, Contracts, and Tax Credits 2023 CLE, National Business Institute (June 2023)
  • Co-Author, “IRS Releases Guidance on Tax Credit Sales and Direct Cash Payments,” Energy Current, Foley & Lardner LLP blog (June 2023)
  • Co-Author, “Treasury and IRS Issue Guidance on Domestic Content Bonus Credit for Renewable Energy Projects,” Energy Current, Foley & Lardner LLP blog (May 2023)
  • Speaker, ACC Houston Energy Practice Group CLE: Hydrogen Incentives and Tax Benefits for Renewable Energy Projects (May 2023)
  • Co-Author, “IRS Releases Guidance on Energy Community Credit Adder,” Energy Current, Foley & Lardner LLP blog (April 2023)
  • Co-Author, “IRS Releases Guidance on Low-Income Community Credit Adder,” Energy Current, Foley & Lardner LLP blog (February 2023)
  • Co-Author, “What’s Next for the ITC and PTC Following the Inflation Reduction Act,” Energy Current, Foley & Lardner LLP blog (August 2022)
  • Guest Speaker, “What’s Next for the ITC and PTC Following the Inflation Reduction Act,” Powered by Foley Podcast (August 2022)
  • Co-Author, “The Inflation Reduction Act: Key Provisions Regarding the ITC and PTC,” Energy Current, Foley & Lardner LLP blog (August 2022)
  • Author, “College Athlete Rights After O’Bannon: Where Do College Athlete Intellectual Property Rights Go from Here?” VAND. J. ENT. & TECH. L. 18 (2016)
July 10, 2025 Foley Viewpoints

Trump Administration Passes the One Big Beautiful Bill Act

On July 4, 2025, President Trump signed H.R. 1—referred to as the One Big Beautiful Bill Act (OBBBA). The OBBBA extends and makes...
July 9, 2025 Energy Current

ITC and PTC Changes Under the Big Beautiful Bill Act

President Trump last week signed into law the One Big Beautiful Bill Act (the “Act”). The Act made a number of changes to the clean...
July 8, 2025 Energy Current

Executive Order on PTC and ITC Beginning of Construction

President Trump yesterday issued an executive order, “Ending Market Distorting Subsidies for Unreliable, Foreign Controlled Energy...
June 16, 2025 Energy Current

U.S. Senate Proposes Changes to ITC and PTC

The Senate Finance Committee has released draft legislation proposing a phasedown of the ITC and PTC for solar and wind projects beginning in 2026. Learn what this could mean for renewable energy developers.
May 13, 2025 Energy Current

High-Level Overview of certain Provisions Impacting Renewable Energy Incentives in “The One, Big, Beautiful Bill” Draft Legislation

The House Ways and Means Committee released a package of tax provisions that includes claw backs of certain provisions of the Inflation Reduction Act.
January 16, 2025 Blogs

Final Regulations for New Clean Energy Production and Investment Tax Credits

Last week, the IRS and Department of the Treasury issued the highly anticipated final regulations for the Clean Electricity Production Tax Credit set forth in Section 45Y of the Internal Revenue Code of 1986.