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Am Law 100 firm with practices in Business, Digital Assets and Data Management, Intellectual Property, Labor & Employment, Litigation and Tax.

Home | BakerHostetler

The Privacy Strategist – Data on (and off) the Playing Field: The Business of Sports Data

BakerHostetler Represents McGohan Brabender in Acquisition by Higginbotham

Elise Elam Joins Panel on AI-Accelerated Adversaries at CrowdTour Columbus

Antitrust Advocate

State Action Update (Part II): Fifth Circuit Reaffirms Narrow Municipal Immunity in <em>Megatel Homes v. City of Mansfield</em>

<p class="BHBodyText">Nicholas’ multidisciplinary tax practice allows him to holistically counsel his clients and provide them with practical and comprehensive solutions that guide them throughout the lifecycle of their commercial transactions. In this regard, Nicholas regularly advises clients on how to mitigate tax risks, as well as enhance the tax efficiency of commercial transactions and operating structures. He regularly advises domestic and multinational companies, private equity funds, technology, renewable energy and non-renewable energy, agriculture, blockchain and manufacturing businesses on all facets of taxation, including renewable energy credits and issues relating to financial products (i.e., character of income, timing of income and issues with respect to hedging), technical and policy issues, transfer pricing, treaties and international tax issues.</p>
<p class="BHBodyText">Nicholas is the co-author of two leading treatises: <i>Financial Products: Taxation, Regulation and Design</i> and <i>Energy and Environmental Project Finance Law and Taxation: New Investment Techniques</i>. Prior to joining the firm, he spent more than six years in public accounting, working in both Chicago and London.</p>

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LL.M., Taxation, Northwestern University Pritzker School of Law, 2014, 

J.D., Chicago-Kent College of Law, Illinois Institute of Technology, 2010, 

B.A., University of Michigan, 2006

<ul>
<li><em>Lawdragon</em> 500 Leading Global Tax Lawyers (2026)</li>
<li><em>The Best Lawyers in America®</em>
<ul>
<li>&#8220;Ones to Watch&#8221; in Washington, D.C., for Tax Law (2024 to 2025)</li>
</ul>
</li>
<li><em>JD Supra </em>Readers’ Choice Awards: Top 10 Author in Tax (2024)</li>
<li>The Legal 500 United States
<ul>
<li>Recommended in Tax: International Tax (2024)</li>
<li>Recommended in Tax: Contentious (2021 to 2025)</li>
</ul>
</li>
<li>Kids in Need of Defense (KIND): Pro Bono Attorney of the Month (Sept. 2020)</li>
<li>“Financial Products: Taxation, Regulation and Design” (Wolters Kluwer): Co-author</li>
<li>“Energy and Environmental Project Finance Law and Taxation: New Investment Techniques” (LexisNexis): Co-author</li>
</ul>


Washington, D.C.

Nicholas Mowbray Provides Insights on Energy Credits’ Foreign Debt Limits to <em>Law360</em>

BakerHostetler attorneys and practice areas spotlighted in the 2026 Legal 500 annual guide

Germany’s New Attack on Disregarded Entities: Baseless Treaty Denial (<em>Tax Notes</em>)

Material Assistance – Newly Issued IRS Guidance

Nicholas Mowbray Participates in Panel at Crowe LLP Energy Summit

Nicholas Mowbray Joins Panel at Novogradac 2025 Fall Renewable Energy Tax Credits Conference

Analysis of Renewable Energy Credit Amendments and Changes Under the 2025 Tax Legislation

BakerHostetler attorneys and practice areas spotlighted in the 2025 Legal 500 annual guide

Renewable Tax Credit Transfers: Overview and Deal Considerations (Journal of Taxation of Financial Products)

Nicholas Mowbray, Glenn Benson, Lucas Witters, Michael Semes Publish Book with LexisNexis

Nicholas Mowbray Presents on Crypto Panel at TEI 2025 Midyear Conference

BakerHostetler Elevates 24 Attorneys to Firm Partnership

Jeff Paravano, Jeremiah Hart, Nicholas Mowbray Author Article for Employee Benefit Plan Review

Jeff Paravano, Nick Mowbray Speak on Panel at IFA USA Cleveland Regional Event

Brian Davis, Nicholas Mowbray Serve as Instructors at US International Tax Course

Nick Mowbray Participates in Strafford Webinar on Purchasing Renewable Energy Credits

Jeff Paravano, Michelle Hervey, Nick Mowbray Speak to Tax Club of Cleveland

BakerHostetler Team Files Amicus Brief Against SEC by The Digital Chamber

Prevailing Wage and Apprenticeship Requirements – Analysis of the Final Regulations

BakerHostetler attorneys, practice areas stand out in The Legal 500 annual guide

Proposed Regulations – Clean Electricity Production and Investment Credits (45Y and 48E)

IRS Heeds Call to Investigate Misuse of Puerto Rican Residency Tax Benefits

BakerHostetler Sponsors Tax Executives Institute Seminar

Monetizing Renewable Credits Part II – Final Regulations on Transfers of Renewable Credits

Jeff Paravano, Nick Mowbray Participate in IFA USA Cleveland Regional Event on Economic Substance Doctrine

Monetizing Renewable Energy Credits – Final Regulations on Direct Pay

Nicholas Mowbray Takes Part in Webinar About New IRS Guidance on Advanced Manufacturing Production Tax Credit

Three BakerHostetler Attorneys and Two Firm-Authored Articles Recognized in 2024 JD Supra Readers’ Choice Awards 

No Further Warnings – Prosecutors Bring First Pure Legal Digital Asset Tax Indictment; More Criminal Cases to Come  

Webinar: Renewable Energy: How Nonprofits Can Utilize Renewable Credits for Campus Projects

Carlos Ortiz, Nicholas Mowbray and Kayley Sullivan Highlight IRS Focus on Digital Assets in Law360 Article

Brian Davis, Nick Mowbray Transfer Pricing Course Offered via TEI Simulive

Overview of the Proposed Regulations for Advanced Manufacturing Credits Under Section 45X

Blockchain Monitor

Non-Fungible Tokens (NFTs): Overview

Crypto Firms Announce New Initiatives; IOSCO, FSB, BIS Publish Digital Asset Reports; OFAC, SEC, DOJ Bring Crypto Actions; Hackers Steal $97M and $50M, *Client Alert*

BakerHostetler represents Clements Worldwide in acquisition by Arthur J. Gallagher & Co.

Crypto + Evasion = Jail – The Government’s Old Math for a New Technology

Paravano, Mowbray and Campbell present at annual Cleveland Tax Institute

Tax Credits for Clean Energy Manufacturing: Sec. 45X vs. Sec. 48, Recent IRS Guidance, Pitfalls to Avoid

BakerHostetler counsels SurgePE through 2 major deals in 2 weeks

BakerHostetler attorneys plan, present at NYSBA International Section global conference

Schmidt and Mowbray speak at Tax Executives Institute conference

Analysis of IRS Proposed Regulations Addressing the Renewable Energy Credit Prevailing Wage and Apprenticeship Requirements

Digital Asset Broker Regulations Target DeFi Platforms and Payment Processors

Are digital assets commodities or securities? Taxpayers need to know

New chapter addresses tax considerations in the use of virtual currencies and other digital assets

Court Upholds Tornado Cash Sanctions; New Crypto Products Launch; IRS Proposes Digital Asset Regulations; Crypto Enforcement and Hacks Continue

Energy industry seeks change to proposed rule on direct pay of tax credits

Davis and Mowbray teach transfer pricing session of tax course

Capital Pro Bono Honor Roll includes 13 BakerHostetler Attorneys

Nicholas Mowbray writes private funds chapter in August 2023 edition of Taxes magazine

Kraken Loses Bid to Avoid Turning Over Customer Information to IRS

Nicholas Mowbray Takes Part in Panel on Inflation Reduction Act Credits

Overview of the Proposed Regulations Addressing Transferring Renewable Credits

Overview of the Proposed Regulations Addressing Direct Pay

Nicholas Mowbray Discusses Federal Tax Credits Available to Nonprofits

BakerHostetler Attorneys and Practice Areas Recognized in The Legal 500 2023 Guide

Nicholas Mowbray Co-Authors Article on Tax Policy Effects of US and EU Laws

Nicholas Mowbray Teaches CLE About New IRS Guidance on Taxation of NFTs

Overview and Observations of Notice 2023-38 – Domestic Content Bonus Requirements

Practical Applications of the Superfund and Methane Taxes, and the Impact of Recently Published Proposed Regulations

Carlos Ortiz, Christina Gotsis and Kayley Sullivan Author Article About IRS Crypto ‘Crackdown’

Nick Mowbray, Robert Musiala and Betsy Smith Authored an Article About Federal Tax on NFTs, with Teresa Goody Guillén Contributing

Risks Associated with the Purchase of Renewable Energy Credits – Part II

Overview of Proposed Regulations – Superfund Taxes

Nicholas Mowbray Addresses New IRS Guidance on Non-Fungible Tokens

Overview of Renewable Energy Tax Credits Under the Inflation Reduction Act – Part I

New Initiatives Launch in Staking, DeFi, DAOs; IRS Issues NFT Guidance; White House Report Criticizes Crypto; SEC and DOJ Crypto Enforcement Continues

IRS Issues Guidance on Non-Fungible Tokens – What It Says and Does Not Say

Nicholas Mowbray Says IRS Guidance on NFTs as Collectibles Would Be Welcome

Supreme Court Rules in Favor of Taxpayer in FBAR Case – Penalty for Non-Willful Violations Apply on a Per-Report Basis

Brian Davis and Nicholas Mowbray Teach at Simulive International Tax Conference

Nicholas Mowbray Quoted About IRS Crypto Memo

Nicholas Mowbray Sheds Light on Tax Treatment of Derivatives

Nicholas Mowbray Quoted in Tax Notes Federal About Crypto Stakes

Nicholas Mowbray Addresses 2022 ABA Fall Tax Meeting

Nicholas Mowbray Explores Tax Implications of Ethereum ‘Merge’

The Tax Man Isn’t Leaving: The IRS Continues to Issue John Doe Summonses Relating to Virtual Currency Transactions

Jeff Paravano, Poe Leggette and Nicholas Mowbray Explain Energy Tax Credits

What’s in It for Me: The Inflation Reduction Act’s Clean Energy Tax Credits

Carlos Ortiz, Nicholas Mowbray, Christina Gotsis and Kayley Sullivan Author Article on IRS Summons to Major Crypto Platform

Carlos Ortiz, Betsy Smith, Nicholas Mowbray, Christina Gotsis and Kayley Sullivan Write Article for the Journal of Taxation of Investments

The Tax Man Is Back: IRS Issues First John Doe Summons in 2022 to Major Crypto Platform, Seeking Treasure Trove of Information on Tax Noncompliance

Brian Davis and Nicholas Mowbray Are Presenters at TEI Tax Course

Inflation Reduction Act Becomes Law

Introduction to Non-Fungible Tokens

Taxation of Non-Fungible Tokens

Nicholas Mowbray Podcast Addresses Superfund Excise Taxes

Services

International Tax

Tax Controversy and Litigation

Transactional Tax

Web3 and Digital Assets

Enterprise Issues

Inflation Reduction Act Tax Credits

Industries

Financial Services: Investment Funds

Digital and Innovative Markets

Renewable Energy Tax Credits

Community Development

2025 Tax Legislation

Central and Eastern Europe

Renewable Energy

<h5>Federal Tax Planning</h5>
<ul>
<li>Advised a private equity fund on a cross-border funding agreement for the development and commercialization of a pharmaceutical product.</li>
<li>Designed and implemented a new non-U.S. structure for a blockchain company that originally incorporated in the U.S.</li>
<li>Advised a U.S. aerospace company with respect to IP licensing and how to structure licensing agreements with a foreign licensee to achieve a foreign-derived intangible income deduction.</li>
<li>Advised a mobile game developer on how to structure game development and operations to mitigate the digital transaction sourcing rules.</li>
<li>Advised a foreign-based manufacturer on the disposal of its U.S. real property interests, including issues arising under the Foreign Investment in Real Property Tax Act.</li>
<li>Advised a digital platform company on its cross-border structure in connection with its launch of its U.S. platform, including addressing permanent establishment and U.S. trade or business considerations and transfer pricing issues.</li>
<li>Advised a U.S. multinational on how to structure a cross border oil and gas venture, including addressing U.S. trade or business and effectively connected income issues, U.S. agency principles, subpart F issues and title passage.</li>
<li>Advised an investment fund on its move to Puerto Rico, establishing Puerto Rican residency and navigating the applicable income sourcing rules</li>
<li>Created and implemented protocols for traders of a non-U.S. hedge fund with respect to publicly traded partnerships and derivatives written over U.S. equities.</li>
<li>Designed and implemented structures for a non-U.S. alternative lending fund with respect to lending and aircraft leasing in the U.S.</li>
<li>Advised U.S. multinational on restructuring considerations with respect to GILTI.</li>
<li>Advised U.S. multinational on functions and services qualifying for FDII.</li>
<li>Designed and implemented the transfer of IP by a U.S. multinational to a foreign subsidiary.</li>
</ul>
<h5><strong>Environmental Tax Issues and Renewable Energy Credits</strong></h5>
<ul>
<li>Advised a battery manufacturer on the implications of the prohibited foreign entity rules and the implementation of a strategy to comply with the material assistance rules.</li>
<li>Advised a solar manufacturer on contractual provisions related to the domestic content requirements and the material assistance requirements, including how to appropriate negotiate an indemnification provision.</li>
<li>Represented a buyer in the purchase of Clean Fuel Production Tax Credits relating to a renewable natural gas facility.</li>
<li>Represented a buyer in the purchase of Clean Fuel Production Tax Credits relating to an ethanol facility.</li>
<li>Represented a buyer in the purchase of Investment Tax Credits relating to solar energy and battery storage systems.</li>
<li>Represented a seller in the sale of Investment Tax Credits for a utility scale solar energy and battery storage system.</li>
<li>Represented a seller in the sale of Advanced Manufacturing Production Credits relating to solar components.</li>
<li>Represented a buyer in the purchase of Advanced Manufacturing Production Credits relating to thermal battery modules.</li>
<li>Advised several battery manufacturers on excise taxes that apply to taxable chemicals, which included submitting a comment letter to the IRS advocating for future guidance.</li>
<li>Advised a multinational chemical manufacturer based in the U.S. on how to revise their vendor agreements to account for exemptions to excise taxes that apply to taxable chemicals.</li>
<li>Advised a manufacturer of structural support systems on the recently enacted Advanced Manufacturing Production Credit and negotiated the provisions of their supplier and vendor agreements related to the Advanced Manufacturing Production Credit.</li>
<li>Represented the developer of a solar facility and advised them on the amendments to the Investment Tax Credits rules and proposed regulations issued by the IRS, including issues relating to energy property, beginning of construction and the prevailing wage and apprenticeship requirements.</li>
<li>Advised a battery manufacturer on the recently enacted Advanced Manufacturing Production Credit and advocated on behalf of the manufacturer in response to the IRS’s request for comments.</li>
<li>Advised a solar tracker multinational company on contract manufacturing arrangements and the Advanced Manufacturing Production Credit.</li>
<li>Represented the developer of a geothermal energy system and advised them on qualifying for Investment Tax Credits, including issues relating to dual use energy property and when the energy property was “placed in service.”</li>
<li>Advised an agricultural company on the fuel production credits that were amended and enacted by the Inflation Reduction Act.</li>
<li>Assisted a multinational bank in designing a lending transaction that utilized as collateral direct pay election proceeds relating to the Advanced Manufacturing Investment Credit.</li>
<li>Advised a carbon capture joint venture on its operating and midstream services agreements related to the capture and disposal of carbon.</li>
<li>Advised a vehicle manufacturer on the Qualifying Advanced Energy Project Credits and the wage and apprenticeship requirements.</li>
</ul>
<h5><strong>Transactional Tax Advice</strong></h5>
<ul>
<li>Advised an investment fund on its disposals of deeply distressed debt instruments, including the proper tax accounting treatment and method.</li>
<li>Created tax-efficient investment strategy for a non-U.S. investor investing in a U.S. broker-dealer.</li>
<li>Designed and implemented the transfer pricing framework for a multinational financial services business.</li>
<li>Created restructuring and entity simplification plan for a U.S. multinational with respect to its non-U.S. holdings in China, Mexico and the Netherlands.</li>
<li>Advised U.S. multinational on how to integrate a non-U.S.-acquired business into its operating model and how to restructure its acquisition indebtedness.</li>
</ul>
<h5>Digital Assets <strong>Advice</strong></h5>
<ul>
<li>Advised a blockchain company on how to structure the operations related to the development of its protocol and eventually issuance of its tokens.</li>
<li>Resolved an IRS controversy related to the trading of cryptocurrencies.</li>
<li>Advised a U.S.-based cryptocurrency trading firm on its relocation to Puerto Rico.</li>
<li>Advised a U.S.-based, high-frequency cryptocurrency trading firm on how to structure its operating model and trading operations.</li>
<li>Advised a U.S. business on matters related to creating and issuing non-fungible tokens as compensation to its employees.</li>
</ul>
<h5><strong>Tax Controversy</strong></h5>
<ul>
<li>Representing a multinational in challenging the validity of a retroactive Treasury regulation.</li>
<li>Negotiated a favorable settlement at IRS appeals for a foreign-based manufacturing company where the IRS proposed transfer pricing adjustments to the company&#8217;s intercompany debt.</li>
<li>Represented a U.S. multinational corporation in connection with an IRS controversy related to what constitutes a cash equivalent asset under Section 965.</li>
<li>Resolved an IRS controversy related to a U.S. multinational’s acquisition and stock issuance costs.</li>
<li>Resolved an IRS controversy related to proposed transfer pricing adjustments to a non-U.S.-based multinational&#8217;s intercompany debt with its U.S. subsidiary.</li>
<li>Settled in Tax Court a controversy related to constructive receipt and when farmers are required to recognize income under their grain contracts.</li>
<li>Advised and represented individuals filing for the IRS’ Voluntary Disclosure Program.</li>
<li>Advised, represented and settled a trust fund recovery investigation relating to millions of dollars of deferred and unpaid FICA taxes.</li>
</ul>
