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Drew M. Young

Drew M. Young

Socio
Transactional Tax Practice Lead – Northeast
Every time we get on the phone with tax counsel from other firms, they all look to Drew Young.
— Client, The Legal 500
New York
About

Drew Young handles a wide range of federal, international, and state and local tax matters for corporations, partnerships and individuals.

Drew's practice focuses on structuring acquisitions, divestitures and reorganizations of multinational companies. He also focuses on tax issues associated with structuring investment funds and their portfolio investments and structuring and financing renewable energy and EV projects, including tax equity financings and tax credit purchases and sales.

Areas of FocusSegurosImpuestosTransactional Tax
Bar admissionsMassachusettsNueva York

EXPERIENCE

  • Advised non-U.S. manufacturer of batteries on the Pillar 2 implications of receiving direct pay under Section 45X or selling such Section 45X tax credits.
  • Advised U.S. multinational company on the Pillar 2 and BEAT implications of purchasing refundable credits under the Inflation Reduction Act.
  • Represented purchaser of $165 million of Section 48 energy tax credits related to rooftop residential solar projects.
  • Represented purchaser of $150 million of Section 48 energy tax credits related to commercial and industrial solar projects. 
  • Issued two tax opinions to a manufacturer of battery storage assets related to qualification of two different types of battery modules for the domestic content bonus credit under Section 48 as a result of manufacturing the batteries in the United States.
  • Advised manufacturer of battery modules and solar inverters on qualification of their battery modules and solar inverters for credits under Section 45X.
  • Issued tax opinions to a manufacturer and developer of hydrogen fuel cells and fuel cell projects on (1) qualification of their different fuel cell products for the domestic content bonus credit under Section 48 as a result of manufacturing the fuel cells and refueling property in the United States, (2) qualification of their storage property for the Section 48 energy tax credits, (3) qualification of their hydrogen production, liquefaction and storage property for the Section 48 energy tax credit for storage technology and the Section 45V hydrogen production credit, (4) responding to requests for comments on proposed Treasury Regulations under the Inflation Reduction Act and challenging the statutory authority for certain proposed Treasury Regulations and (5) other related issues.
  • Ongoing representation of large U.S. solar and wind developer on tax-equity structures and complying with aspects of the Inflation Reduction Act, such as selling tax credits, satisfying the prevailing wage and apprenticeship requirements, the domestic content requirements and energy community bonus credit qualification.
Education
  • LL.M., Taxation, New York University 2008
  • J.D., New England School of Law 2007
  • B.S., Appalachian State University 1999

Awards

The Legal 500 United States

  • Recommended, Energy: Renewable/Alternative Power (2018-2021, 2023-2024)
    "Drew Young’s knowledge, creativity, patience and diligence has been crucial." – Client, The Legal 500 (2023)
    "Also recommended is Drew Young, who handles both federal and SALT matters." – Client, The Legal 500 (2021)

Publications

  • Proposed regulations clarify Foreign Entity of Concern exclusions from Clean Vehicle Tax Credits, 05 December 2023
  • IRS releases proposed regulations on transferring certain renewable energy credits, 27 June 2023
  • IRS publishes additional guidance on the Section 48C Advanced Energy Project Tax Credit, 13 June 2023
  • IRS says regularly traded stock exception to FIRPTA applies at the partnership/fund level, 01 June 2023
  • Access energy funding opportunities by the US government, 03 May 2023
  • Navigating New York City’s Local Law 97 – issues and challenges, 24 January 2023
  • Treasury Department, IRS issue “directional” guidance on clean vehicle credit provisions of the Inflation Reduction Act, 10 January 2023
  • Treasury and IRS provide interim guidance on stock repurchase excise tax: headline points, 04 January 2023
  • The clean energy provisions of the Inflation Reduction Act of 2022 – a historic effort to encourage the development of clean energy and reduce carbon emissions, 17 August 2022

Prior Experience

While in law school, Drew participated in a clinic at the Massachusetts Appellate Tax Board, working on a Commerce Clause case involving a leading financial services provider, and worked as a law clerk in a leading state and local tax practice.

Before becoming a lawyer, Drew served as vice-president and a director of a consulting firm operating in Canada, New Zealand and South Korea. At various times, Drew lived in each of these countries and regularly traveled between the firm's seven offices, serving small businesses and entrepreneurs.

My latest insights

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DLA Piper advises Corum Asset Management in first US real estate investment

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Publication

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22 de octubre de 2024 .6 minute read

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Phone

+1 212 335 4883
(Work, New York)
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