Introduction

Emily is an associate in Fredrikson & Byron’s Tax Planning & Business Organization and Energy Groups. She is a tax lawyer with an emphasis on optimizing tax outcomes for project finance transactions, including renewable energy and private equity. 

Emily’s renewable energy work includes structuring wind, solar, and biomass transactions to take advantage of federal incentives and subsidies, including the Production Tax Credit, Investment Tax Credit, New Markets Tax Credit, and USDA guaranteed loans under Section 9003 and the Business & Industry programs, among others.

Emily’s business law practice covers all phases of the business cycle, from counseling start-up clients trying to secure development funding to helping clients buy and sell established businesses. In particular, she has experience working with private equity groups, mezzanine lending organizations, and family-owned businesses.

In addition, Emily counsels nonprofits and tax-exempt clients on tax and governance compliance. She is on the Board of a tax-exempt entity and has assisted several others facing automatic revocation and Attorney General inquiries.

Prior to joining Fredrikson & Byron, Emily worked as a tax associate for a Minneapolis law firm where she analyzed and structured financing transactions including a variety of tax credits, transactions including New Markets Tax Credits, and public-private joint ventures. Emily counseled lenders, finance companies, corporations, and partnerships on a variety of tax issues including SEC filings and various reorganizations. Emily gained additional experience clerking for the Honorable Mark V. Holmes at the United States Tax Court in Washington D.C.

Education

• University of Minnesota Law School, J.D., 2008
• University of Michigan, B.A., 2005

Bar Admissions

• Minnesota, 2009

Practice Areas

• Tax Planning & Business Organization
• Tax Credit and Incentive Financing
• Corporate
• Mergers & Acquisitions
• Energy
• Renewable Energy

Representative Experience

• Coordinated and structured several transactions combining various USDA grants with other federal incentives
• Structured transactions to take advantage of more than $180 million in Section 1603 cash grants
• Negotiated gross up terms in an earn-out provision saving the client more than $8 million in taxes
• Formed and successfully requested tax exemption for several nonprofit organizations
• Counseled tax credit sellers and structured more than 15 New Markets Tax Credit transactions
• Counseled partnership and corporate clients on tax effects of debt workouts, anti-churning laws, and tax-free reorganizations
• Performed tax due diligence and tax structuring for $350 million IPO involving real estate investment trust

Selected Publications & Presentations

• “Escaping the Credit Crunch: Using Government Incentives to Finance Biomass Production,” co-authored with Todd Taylor, December 2011

Professional Activities

• American Bar Association
• Minnesota Bar Association
• Minnesota Women Lawyers

Honors & Distinctions

• Minnesota Journal of International Law, Editor
• Order of the Coif

Community Involvement

• Underdog Rescue, Volunteer
• Dress for Success Twin Cities, Board of Directors and pro bono counsel