A partner in the Tax Department, Jim Cole practices transactional tax law involving mergers, acquisitions, financings, restructurings and capital markets transactions, with a particular focus on structures designed to efficiently monetize tax credits and other tax attributes. Jim regularly advises strategic and financial sponsors, lenders and investment banks on transactions across the energy industry, including the upstream, midstream, downstream, oil field services and alternative energy sectors.
Jim is ranked by Chambers in the Tax category (2021-2025), recognized by The Best Lawyers in America for his work in Tax Law (2024-2025) and was named in Turnarounds & Workouts’ lists of Bankruptcy Tax Specialists in the Nation’s Major Law Firms (2020-2021, 2023).
Prior to law school, Jim practiced as a Certified Public Accountant in the tax practice of an international accounting firm.
Jim’s representative matters have included:
Alternative Energy Financings
- Apex Clean Energy in the tax equity financing of the:
- Prosperity Wind facility
- Downeast Wind project
- Ara Partners in connection with the monetization of tax credits related to multiple portfolio companies
- Ares EIF in:
- the project development, financing and tax equity financing of the Aviator wind project, and the subsequent divestiture to CMS Energy and Kansai Electric Power Co.
- its sale of its interest in multiple solar tax equity funds to Basalt
- the provision of capital to Swell Energy and the associated structuring and formation of a solar tax equity fund
- numerous structured equity investments designed to optimize tax profile and facilitate efficient capital deployment for strategic sponsors
- Avangrid in the joint venture financing of a wind farm in South Dakota
- Chevron USA in the investment in and development of multiple clean energy projects
- ConnectGen, a portfolio company of Quantum Energy Partners, in an equity investment in, and the tax equity financing of, three solar projects in various states
- A consortium of private equity funds in a preferred investment into a solar developer with a project pipeline in excess of 1.6-GW
- Cordelio Power in the acquisition and development of a pipeline of wind and solar projects
- D. E. Shaw Renewable Investments in an inverted lease financing of a wind farm in Oregon
- Divert in:
- the financing of its new Integrated Diversion & Energy Facility in Longview, Washington, which is the first project to be built under the terms of a $1 billion Infrastructure Agreement with Enbridge
- its $1 billion Infrastructure Development Agreement with Enbridge and $100 million equity financing
- Enfinity Global in the tax equity financing of the Saturn project
- Harvestone Low Carbon Partners in a first-of-its-kind carbon capture and sequestration tax equity financing with Bank of America, which IJGlobal recognized as the Value-Add Deal of the Year in North America
- A leading European alternative energy developer in multiple single project and portfolio tax equity financings relating to both production tax credits and investment tax credits for projects in multiple states
- Lenders in a PAYGO financing of multiple wind projects involving collateralization of federal tax credits
- Middle River Power in the debt and tax equity financing of a battery storage facilities associates with thermal generation assets
- Origis Energy in the:
- $340 million tax equity investment with Crux for a utility scale solar project
- $415 million of debt financing and tax equity financing for the Swift Air Solar Project
- $71 million tax equity financing for Rice Creek Solar Project in Florida
- tax equity financing for the Wheatland Project
- tax equity financing for the Optimist project
- Ørsted Onshore North America in the tax equity financing of a 460-MW combined solar and storage facility
- Parliament Solar in connection with the debt and tax equity financing of multiple Texas based solar projects
- Power Sustainable and Potentia Renewables in an investment in Desert Quartzite Solar+Storage Project
- A publicly traded midstream infrastructure company in connection with the development of a carbon capture, utilization and storage project in Texas and subsequent monetization of Section 45Q tax credits
- A publicly traded natural gas producer in connection with the monetization of Section 45Z Credits
- Radial Power in the $355 million debt and tax equity financing for 214 MW of distributed solar capacity across 106 projects nationwide
- Terra-Gen in the tax equity financing and project financing for the second phase of its Edwards Sanborn Project, the largest single solar and battery energy storage project to reach this milestone to date
- Torch Clean Energy in its strategic partnership with Morgan Stanley Infrastructure Partners to expand and transition the Torch Platform
- Vanguard Renewables in connection with a portfolio tax equity financing of multiple renewable natural gas (RNG) projects
- Vivint in the structuring of a tax equity financing for a portfolio of residential rooftop solar systems
Restructuring
- Alta Mesa Resources in its completed chapter 11
- American Energy Permian Basin in its out-of-court restructuring of $2.2 billion of funded debt
- Arclight Capital Partners in the chapter 11 restructuring of Bruin E&P Partners
- Emerge Energy Services in its completed chapter 11 reorganization
- Lonestar Resources US in its chapter 11 restructuring
- Pinegate Renewables in its chapter 11 restructuring
- Sable Permian Resources in its chapter 11 restructuring
- Stone Energy Corporation in its completed chapter 11 reorganization
- Superior Energy Services in its chapter 11 restructuring
M&A
- Altus Power, the largest owner of commercial-scale solar in the US, in its $2.2 billion take private by TPG
- Arch Resources in its merger with CONSOL Energy, creating Core Natural Resources, a natural resource company focused on global markets
- Archrock in its:
- $357 million acquisition of Natural Gas Compression Systems
- $600 million take-private of Archrock Partners
- Centennial Resource Development in its $7 billion merger with Colgate Energy Partners III, to create the largest pure-play E&P company in the Delaware Basin
- Chesapeake Energy in its combination with Southwestern Energy
- Citadel in connection with its acquisition of Paloma Resources
- CNX Resources in the:
- acquisition of the remaining public stake of CNXM
- elimination of the incentive distribution rights of CNXM
- Colgate Energy Partners III in its acquisition of Luxe Energy in an all-stock transaction
- Consol Energy in its acquisition of the remaining public stake of Consol Coal Resources
- Consolidated Edison in the sale of Con Edison Clean Energy Businesses and its subsidiaries to RWE Renewables Americas
- Consortium investor in the $1.0+ billion preferred equity financing for Blue Source Sustainable Forests Co. (BSFC) and BSFC’s acquisition of1.7 million acres of timberland
- CPP Investments and Cordelio Power in its merger with Pattern Energy, a clean energy and transmission infrastructure company
- CPP Investments and Encino Energy in the $5.6 billion sale of Encino Acquisition Partners to EOG Resources
- CPP Investments in connection with its investment into a consortium acquiring Allete
- Crimson Renewable Energy in the sale of its used cooking oil collection and aggregation business to Neste, the world's leading producer of renewable diesel and sustainable aviation fuel
- Development Capital Resources in its $165 million drilling and development joint venture with a private operator in the Permian Basin
- EDF Renewables North America in the sale of a minority stake in PowerFlex to Manulife IM, as well as a separate acquisition by Manulife IM of a portfolio of operational distributed solar generation and storage projects developed by PowerFlex
- EnCap Energy Transition and PowerTransitions in the sale of PowerTransitions to Partners Group
- EQT Corporation in its $2.93 billion acquisition of Alta Resources Development, an exploration and production company
- Flame Acquisition Corp. in its business combination with Sable Offshore Corp
- H2B2 Electrolysis Technologies in its business combination with RMG Acquisition Corporation III
- Inspiration Mobility in its $200 million capital commitment from ArcLight Energy Partners Fund VII and EV fleet lease partnership with ridehail innovator Revel
- Linode in its acquisition by Akamai Technologies
- Lucid Energy Group in its $3.55 billion acquisition by Targa Resources Corp
- MOD Pizza in its acquisition by Elite Restaurant Group
- NextDecade in the development and financing of the Rio Grande LNG project, the largest greenfield energy equity and debt project financing in US history
- Nine Point Energy in the $250 million sale of its Williston Basin assets to Bowline Energy
- Ørsted in multiple cash equity transactions relating to wind and solar portfolios
- Partners Group in its acquisition of a controlling stake in Dimension Renewable Energy, a distributed energy platform focusing on community solar and battery storage across the US
- Priority Power in its acquisition by I Squared Capital
- RealWear in its business combination with Cascadia Acquisition Corp.
- Sixth Street Partners in connection with its acquisition of developed and undeveloped oil and gas assets
- Talos Energy in its sale of Talos Low Carbon Solutions, a carbon capture and sequestration business, to TotalEnergies E&P USA
- Targa Resources Corp. in its $1.25 billion acquisition of Stakeholder Midstream
- TotalEnergies in its $250 million acquisition of SunPower's Commercial and Industrial Solutions Business
- Vencer Energy in its $2.15 billion sale of assets to Civitas Resources
- Wall Box Chargers, a provider of electric vehicle-charging solutions, in the de-SPAC merger with Kensington Capital Acquisition Coro. II
