Tori Roessler is a partner in the Tax Practice Group in Foley’s Washington, D.C. office. She advises investors, developers, manufacturers, and corporate taxpayers on federal income tax issues related to renewable energy and energy transition projects, with a focus on tax equity financings and tax credit transfer transactions. 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.
She is involved in transaction structuring, daily deal management, negotiations with counterparties, and drafting and negotiating tax provisions in key project and financing documents. Clients rely on her to navigate complex tax rules that underpin the economics of large-scale solar, battery energy storage, hydrogen, carbon capture, and advanced manufacturing projects.
Tori has significant experience with investment (ITC) and production tax credits (PTC), tax credit transfers, advanced manufacturing production tax credits (45X), hydrogen production tax credits (45V), carbon capture tax credits (45Q), and clean fuel production credits (45Z). She frequently advises clients on start of construction strategies, prevailing wage and apprenticeship compliance, and eligibility for domestic content, energy community, and low-income community bonus credits.
In addition to her transactional practice, Tori is a frequent author and speaker on renewable energy-related tax issues. She has written and presented on topics such as advanced manufacturing and hydrogen tax credits, bonus credit rules, tax credit transfers, and direct pay, and she regularly provides internal trainings and webinars on start of construction requirements and prevailing wage, and apprenticeship requirements. She is an active member of Foley’s Energy Industry Team and Energy Transition Team.
Tori is also committed to firm stewardship. She serves on the Washington, D.C. recruiting committee, participates in on-campus interviews and law school outreach, and mentors junior associates in the D.C. office and across the Energy Industry Team.
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)
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IRS Releases Guidance Regarding “Material Assistance” Rules
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IRS Releases Proposed Regulations for Section 45Z Clean Fuel Production Credit
Foley Names 18 New Partners
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Treasury Releases New Beginning of Construction Guidance for Wind and Solar
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Trump Administration Passes the One Big Beautiful Bill Act
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