Drew M. Young

Drew M. Young

Partner
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 advises corporations, investment funds, sponsors, developers, and investors on federal, international, and state and local tax matters, with a focus on complex transactions, including mergers and acquisitions, divestitures, restructurings, and investment fund formations.

Drew is a key member of DLA Piper's energy sector, advising on the structuring, financing, development, acquisition, and disposition of renewable energy, battery storage, EV, and advanced manufacturing projects. He regularly counsels clients on clean energy tax incentives, including investment tax credits (ITCs), production tax credits (PTCs), advanced manufacturing credits, and related bonus credit programs.

He is particularly active in the transferable tax credit market, representing buyers and sellers in tax credit purchase and sale transactions. Drew also advises on tax equity financings and other tax credit monetization strategies designed to maximize value while mitigating risk.

A significant portion of Drew's practice focuses on advising clients on tax credit qualification issues, such as the prohibited foreign entity and material assistance cost ratio rules in the One Big Beautiful Bill Act and the domestic content rules in the Inflation Reduction Act.

Drawing on experience across tax, energy, and fund-related transactions, Drew helps clients navigate the intersection of tax incentives, project finance, and regulatory compliance to efficiently execute sophisticated transactions and realize the full value of available tax credits.

Areas of FocusInsuranceTaxTransactional Tax
Bar admissionsMassachusettsNew York

EXPERIENCE

  • Advised Grupo Cox (Cox), a leading Spanish multinational water and energy company, in its acquisition of Iberdrola’s power generation assets in Mexico for US$4.2 billion
  • 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

Awards

Chambers USA

  • Band 5, New York Tax, (2026)

The Legal 500 United States

  • Recommended, US Taxes: Non-contentious, (2018 – 2021, 2023 – 2026)
  • Recommended, Energy: Renewable/Alternative Power, (2018 – 2021, 2023 – 2024, 2026)
Education
  • LL.M., Taxation, New York University
  • J.D., New England School of Law
  • B.S., Appalachian State University

Publications

  • Proposed regulations clarify Foreign Entity of Concern exclusions from Clean Vehicle Tax Credits, December 5, 2023
  • IRS releases proposed regulations on transferring certain renewable energy credits, June 27, 2023
  • IRS publishes additional guidance on the Section 48C Advanced Energy Project Tax Credit, June 13, 2023
  • IRS says regularly traded stock exception to FIRPTA applies at the partnership/fund level, June 1, 2023
  • Access energy funding opportunities by the US government, May 3, 2023
  • Navigating New York City’s Local Law 97 – issues and challenges, January 24, 2023
  • Treasury Department, IRS issue “directional” guidance on clean vehicle credit provisions of the Inflation Reduction Act, January 10, 2023
  • Treasury and IRS provide interim guidance on stock repurchase excise tax: headline points, January 4, 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, August 17, 2022

Media Mentions

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

News
Abstract blue and purple building

DLA Piper advises Einride on business combination and U.S. listing

16 June 2026 .2 minute read

News
Solar panel

DLA Piper advises Doral Renewables on US$575 million credit facilities

27 March 2026 .2 minute read

Publication
Freight trucks at a warehouse

IRS Notice 2026-15 provides guidance on credit eligibility for certain cross-border supply...

18 February 2026

View All
CallvCardLinkedInPrint

Connect

Phone

+1 212 335 4883
(Work, New York)