Elizabeth Crouse
Partner
Overview
Elizabeth Crouse is a tax attorney in Holland & Knight's Portland office. For more than a decade, Ms. Crouse has provided business-focused solutions for U.S. federal, state and international tax problems in a variety of transactions and investment structures.
Ms. Crouse advises clients – including top-tier strategic and corporate investors, developers and operators in the renewable energy and fuels, hydrogen and carbon capture industries – on a range of U.S. federal income tax matters, including investment tax credits (ITC) for renewable electricity and renewable natural gas (RNG), production tax credits (PTC) for renewable electricity, hydrogen, sustainable aviation fuels (SAF) and clean fuels, and the Section 45Q tax credit for carbon capture and sequestration. She also works with clients to obtain federal government funding for manufacturing facilities in the renewable and carbon capture industries.
In addition, Ms. Crouse provides tax counseling for tax equity investments and the acquisitions and dispositions of projects and platforms, as well as the structuring and coordination of project finance transactions. She also has negotiated more than 3 gigawatts of safe harbor procurement contracts for renewable electricity projects and many more for renewable fuels projects. Ms. Crouse also works collaboratively with clients and colleagues on venture investments in climate tech companies, corporate sustainability programs, and private and public finance.
Nationally recognized in the industry, Ms. Crouse is a frequent speaker at national and regional conferences and webinars on topics such as tax credits for renewable electricity, renewable hydrogen, renewable natural gas, energy storage and carbon capture, as well as environmental, social and governance (ESG), and corporate sustainability topics.
Prior to joining Holland & Knight, Ms. Crouse was an attorney at an international law firm in its Portland office.
Representative Experience
- Negotiated more than 11 gigawatts (GW) worth of investment, procurement, development and mergers and acquisitions (M&A) contracts for U.S. renewable energy developers, investors and syndicators
- Represented a major global retailer in a more than $100 million tax equity investment in a portfolio of community solar projects in New York
- Represented a major global software company in a more than $350 million tax equity investment in a solar and battery energy storage facility in Arizona
- Represented a global apparel and footwear holding company in an $80 million tax equity investment in multiple solar facilities in the southeastern United States
- Represented a regional bank acquirer in several sale leaseback financings of commercial and industrial solar facilities
- Represented a syndicator in tax equity financings of more than 1 GW of solar generation facilities
- Represented a developer in a nearly $200 million tax equity financing of a solar facility in the southeastern United States
- Represented a top 10 U.S. independent power producer in more than $300 million of solar acquisitions
- Served as tax counsel on more than 30 solar, wind and battery acquisition agreements, including early-stage development portfolios, pre-notice to proceed projects and post-placement in service projects and portfolios
- Negotiated the financing and counseled a wastewater natural gas developer on legal and tax structure, and coordinated completion of a full suite of related development contracts
- Counseled a major U.S. dairy renewable natural gas developer on project development and maximization of U.S. federal income tax credits created under the Inflation Reduction Act (IRA)
- Counseled a major U.S. landfill renewable natural gas developer on project development and maximization of U.S. federal income tax credits created under the IRA
- Counseled a major U.S. mixed feedstock renewable natural gas developer on project development and finance models, as well as maximization of U.S. federal income tax credits created under the IRA
- Representing an e-methanol production company regarding U.S. structuring and project development
- Representing a municipal authority in the development of an electrolytic hydrogen production and fueling facility, together with related power supply and offtake agreement
- Represented a major global retail company in the negotiation of U.S. federal income tax credit considerations in respect of multiple significant electrolytic hydrogen offtake agreements
- Represented the Pacific Northwest Hydrogen Hub regarding organization, governance and compliance with respect to a U.S. Department of Energy (DOE) Hydrogen Hub grant proposal
- Counseled a direct air capture project developer and technology company on U.S. federal income tax credit qualification and structuring for multiple facilities in the United States; assisted with project finance planning for same entities
- Counseled a novel carbon utilization technology company on U.S. federal income tax credit qualification for technology in various applications in the U.S.
- Advised a liquefied natural gas (LNG) project developer on U.S. federal income tax credit qualification and structuring for a facility in Texas
- Represented a multinational electricity and fuels operator in rulemaking procedure concerning U.S. federal income tax credits for carbon capture and sequestration
- Represented a global corporate investor in respect to U.S. federal income tax implications of its investment in an advanced development stage direct air capture company
- Negotiated a private equity investment in a direct air capture company
- Advised an international retailer on the legal and financial structure of a real estate and operating assets portfolio
- Advised a multinational renewable natural gas producer on the legal, tax and intercompany financial structure of a U.S. real estate and operating assets portfolio
- Advised a U.S. contract manufacturer of consumer goods on tax and legal considerations of the transfer of operations to the People's Republic of China and implementation of operations
Credentials
- New York University School of Law, LL.M., Taxation
- University of Michigan Law School, J.D., cum laude
- University of Hawaii at Manoa, M.A., Sociology
- Hawaii Pacific University, B.A., Applied Sociology
- Oregon
- Washington
- U.S. Court of Appeals for the Federal Circuit
- U.S. Tax Court
- Women of Renewable Industries and Sustainable Energy (WRISE), Seattle Chapter, Co-Chair, 2017-Present
- Washington State Bar Association (WSBA), Taxation Section, International Tax Subcommittee, Co-Chair, 2014-2018
- Renewable Hydrogen Alliance, Oregon Policy Subcommittee, Chair
- Pacific Northwest Hydrogen Association (PNWH2), Advisory Committee
- The Best Lawyers in America guide, Energy Law and Tax Law, 2022-2024
- Rising Star, Washington Super Lawyers magazine, 2017-2020