For those who have not been following the development of entity structures used to access capital markets for the renewable-energy industry, you might have missed the latest model to turn heads. But the Sol-Wind story is worth noting: It reminds us that capital markets are the true determinant of a structure’s success — no matter how creative the structure dreamt up by securities lawyers and tax planners.

In December 2014, Sol-Wind Renew­able Power L.P. filed a Form S-1 for its initial public offering to issue $410 million (at the high end) in units. The capital was to be used to acquire interests in a 185-megawatt portfolio of solar- and wind-power assets from its general partner. The issuing entity is a limited partnership that holds the stock of a corporation that would in turn invest in tax-equity partnerships owning project limited liability companies. The Sol-Wind structure, simply put, is that of a master limited partnership (MLP) on top of a “yieldco.”

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