Michael Sykes

Michael advises clients on a wide variety of tax matters relating to renewable energy projects including solar and wind projects and projects involving carbon capture and sequestration (CCS). His experience includes advising clients on energy credits (ITC, PTC, and 45Q), partnership structures for tax equity investments, and corporate transactions including mergers and acquisitions, 338 elections, and capital raises involving 1202 Qualified Small Business Stock.

Michael has also advised clients on the tax aspects of inbound investments in U.S. energy projects, compliance requirements for fuel-pathways and CCS projects under low carbon fuel standard programs (LCFS), and various matters relating to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). 

Prior to joining Allen & Overy, Michael served as a judicial law clerk to the Honorable David Gustafson at the United States Tax Court—advising on relevant cases involving energy tax credits, partnership bona fides, At-Risk loss limitations, and various other tax issues. Prior to the Tax Court, Michael’s practice focused on tax controversy and administrative proceedings with the Internal Revenue Service (IRS) during which he representing clients in all aspects of examinations, appeals, and voluntary disclosures.