Boutique Tax Law · Renewable Energy Tax Equity · Draper, Utah

Tax counsel for solar tax equity and clean energy credit transfers

Olson & Partners Law structures direct investment solar tax equity transactions for investors and developers and advises on the transfer of clean energy tax credits under Section 6418.

The firm has structured or advised on over 50 direct solar tax equity transactions in the last 12 months and more than $50 million in renewable energy tax credit transfers since 2024, with additional work in federal tax planning, entity structuring, tax controversy, and digital asset compliance.

Email the firm Call (213) 500-9105

Practice Areas

Focused federal tax counsel for high-stakes transactions.

Section 48E · Direct Investment Tax Equity · Section 6418 Credit Transfers

Renewable Energy Tax

We structure direct investment solar tax equity transactions, advise on clean electricity investment tax credit qualification, and support credit transfer transactions from project sourcing through placed-in-service compliance.

Direct investment solar tax equity structuring
Section 48E clean electricity ITC qualification and compliance
Section 6418 credit transfer agreements and buyer/seller representation
Tax equity investor diligence, opinion support, and reporting frameworks

Federal Tax · LLCs & Partnerships · QSBS · Qualified Opportunity Zones

Tax Planning & Entity Structuring

We advise individuals and businesses on federal income tax planning, tax-efficient entity design, multi-class LLC operating agreements, holding company structures, QSBS, opportunity zones, and related deferral strategies.

Federal income tax planning and compliance
Multi-class LLC and partnership operating agreements
Qualified small business stock and opportunity zone structuring
Installment sales, like-kind exchanges, and other deferral planning

IRS Audits · Appeals · U.S. Tax Court Litigation

Tax Controversy

We represent taxpayers in disputes with the Internal Revenue Service, including audit defense, administrative appeals, U.S. Tax Court litigation, penalty defense, and reasonable reliance opinion support.

IRS audit representation and examination defense
Administrative appeals and settlement negotiations
U.S. Tax Court litigation
Accuracy-related penalty defense and reasonable reliance opinions

Federal Tax Reporting · Classification · Basis Support

Digital Asset Compliance

Digital assets remain a secondary practice area. When those issues arise for clients, we advise on federal tax reporting, asset classification, and basis support within the broader tax advisory relationship.

Digital asset transaction reporting and compliance
Token classification and tax characterization
Cost basis methodology review
Coordination with broader federal tax planning and controversy needs

Team

Tax law, transaction judgment, and operator-level execution.

Experienced tax counsel supported by practical transaction and operations judgment.

Ephraim Olson

Member

Advises developers, investors, fund sponsors, and professional advisors on renewable energy tax credits, solar tax equity transactions, credit transfers, and complex federal tax planning.

Renewable Energy TaxTax EquityFederal Tax Planning

Nate Bradshaw

Member

Nate Bradshaw is a seasoned entrepreneur, business executive, and tax strategy leader with more than a decade of experience building and scaling companies across tax advisory, renewable energy, legal services, software, e-commerce, and financial strategy. As Co-Founder and COO of B10 Energy, Nate helped build one of the leading platforms for Renewable Energy Tax Credits, including contracting the transfer of more than $200 million in credits under the Inflation Reduction Act and helping the company earn Inc. 5000 recognition in 2024 and 2025. He brings operational expertise to the organization in driving a practical, operator-level perspective on tax planning, accounting systems, business growth, compliance, and financial decision-making. Nate's work focuses on building systems and processes that help business owners and high-net-worth clients uncover opportunities, improve cash flow, and execute sophisticated financial strategies with clarity and confidence.

Tax StrategyOperationsRenewable Energy

Derek Wride

Member (non-lawyer)

Supports tax strategy operations, client coordination, and implementation workflows so advisory work can translate into practical outcomes for clients and referral partners.

Tax StrategyOperationsClient Coordination

Insights

Practical analysis for advisors navigating solar tax incentives.

Articles are written for CPAs, wealth advisors, tax attorneys, and professional advisors evaluating solar tax equity, credit transfers, and federal tax planning opportunities.

View all insights

Ephraim Olson · April 28, 2026

How §48E Credits and Bonus Depreciation Work Together in Solar Tax Equity

A plain-language explanation of the two main federal tax benefits in a direct investment solar transaction and how the combined economics work for a tax equity investor.

Ephraim Olson · May 5, 2026

The §48E Solar ITC Terminates at the End of 2027: What Advisors Need to Know Now

A practical overview of the beginning-of-construction safe harbor, placed-in-service deadlines, and what the compressed timeline means for investors and advisors.

Ephraim Olson · May 12, 2026

FEOC Rules and Solar Tax Credits: What We Know, What We Don't, and What to Do Now

A due diligence framework for foreign entity of concern restrictions, material assistance calculations, and upstream supply chain exposure.

Ephraim Olson · May 19, 2026

The Material Participation Rule Most Professionals Don't Know

How the substantially-all-work material participation rule can matter for solar system ownership and passive activity loss planning.

Contact

Speak with the firm about a transaction or tax position.

We work with CPAs, tax attorneys, wealth advisors, project developers, credit buyers, and investors on solar tax equity structuring, credit transfers, and complex federal tax matters.

Email ephraim@olsonpartnerslaw.com Phone (213) 500-9105 Location

Draper, Utah