Sam Kamyans, P.C.

Partner Tax

Overview

Sam Kamyans is a partner in the Tax Practice Group in the Washington, D.C., office of Kirkland & Ellis LLP. He is known as a “very talented” advisor in partnership taxation, uniquely in structuring tax-driven transactions to invest in, finance, or acquire carbon capture, hydrogen, clean fuels, solar, storage, and other energy transition projects. Sam has developed tax structures to implement market leading transactions relying upon section 45Q, 45Z, 45V, and 45/48 credits. He advises energy clients, including domestic and international private equity funds, and major sponsors to structure creative transactions to optimize each clients’ commercial and tax goals.

In addition, Sam brings a solutions-oriented approach to structure and implement mergers and acquisitions, divestitures, equity extractions, distressed asset restructurings, and public and private offerings.

In addition, Sam frequently publishes articles that clients rely upon to structure their deals, including a carbon capture financing guide, a guide to evaluating how to optimize credits for multi-credit projects, and practical publications on implementing IRS guidance.

Prior to joining Kirkland, Sam served at the Internal Revenue Service, where he assisted in issuing guidance on partnership taxation and energy-related matters. He has also served as tax counsel to Sempra Energy, a Fortune 500 energy company, and as a partner at a prominent U.S. energy-focused firm.

Sam is a Chambers ranked attorney in Projects: Renewables & Alternative Energy. Sam is recognized in the 2024 edition of The Legal 500 United States for Project Finance as a “Next Generation Partner.” He is also recognized in The Legal 500 United States for Energy: Renewable/Alternative Power (2020 and 2024), Energy Transactions: Electrical Power (2024), International Tax (2024), and US Taxes: Non-Contentious (2024) as well as in The Legal 500 Latin America for Projects and Energy (2021).

More

Thought Leadership

Publications

Author, “IRS Must Defer to Industry Pacts for Carbon Capture Tax Credits,” Bloomberg, October 2024

Author, “The Inflation Reduction Act: How new rules fuel new financings,” Infrastructure Investor, November 2023

Author, “Proposed Transferability Regulations – A Practical Guide to Accelerate Tax Credit Transfers,” June 16, 2023

Author, “Decoding the Tax and Climate Law’s ‘Green’ Credit Complexities,” Bloomberg Tax, March 21, 2023

Co-author, “Financing US Carbon Capture Projects,” Project Finance International, May 6, 2021 

Co-author, “Carbon Capture Tax Credit Gets a Boost From IRS Guidance – A Practical Guide for Investors,” Tax Alert, February 21, 2020

Author, “ITC Phasing Down While Ramping Up,” Project Finance International Yearbook, 2020

Speaking Engagements 

Speaker, “Financing Hydrogen Projects,” World Hydrogen North American Conference, May 22, 2023

Speaker, “Q&A on Transferable Tax Credits with Tax, Legal, and Energy Experts,”  Crux Webinar, May 3, 2023

Podcasts

“Voluntary carbon credits – an in depth look,” The Allen & Overy Podcast, December 1, 2022

Recognition

Projects: Renewables & Alternative Energy, Chambers Global: USA (2024)

Projects: Renewables & Alternative Energy – Nationwide, Chambers USA (2023–2024)

The Legal 500 United States for Project Finance as a “Next Generation Partner” (2024)

The Legal 500 United States for Energy: Renewable/Alternative Power (2020 and 2024), Energy Transactions: Electric Power (2024), International Tax (2024), and US Taxes: Non-Contentious (2024)

The Legal 500 Latin America for Projects and Energy (2021)

Credentials

Admissions & Qualifications

  • District of Columbia
  • California (inactive)

Education

  • Georgetown University Law CenterLL.M., Taxation
    with Distinction
  • Loyola Law School, Los AngelesJ.D.
  • University of California, Santa BarbaraB.S.