Susan L. Rogers

Susan Rogers is a Partner in the firm’s Taxation group.  She has three decades of experience advising clients on federal and international tax issues with extensive experience coordinating US and global tax policy issues for a leading Fortune 100 energy multinational company and several years as Majority Tax Counsel to the U.S. House Ways & Means Committee.

Ms. Rogers advises clients on tax credits and incentives available in a broad range of categories including energy, manufacturing, infrastructure, employment, small business, and health care. She has represented businesses in a variety of sectors including renewable energy, energy generally, retail, manufacturing, health, hospitality, services, media, and consulting.

Ms. Rogers advises US and international businesses on federal, foreign, and key state tax issues related to tax credits and incentives, and their utilization in business transactions, investments, financings, and ongoing business operations with expertise in energy project document drafting and review with the goal of mitigating risk related to qualification and compliance.

She is an expert in the field of tax policy developments with broad experience in Washington, D.C., related to the tax legislative and regulatory process with a focus on review of Treasury and IRS regulatory guidance.

Representative Experience

Energy Tax including Renewable Energy Incentives

• Counsel to several renewable energy developers and manufacturers on energy tax credit and incentive issues included in the Inflation Reduction Act of 2022 and the One Big Beautiful Bill Act of 2025 and how to manage qualification for the tax credits, compliance rules, and risk management.
• Advises several clients including for-profit and non-profit businesses on a variety of tax code rules affecting renewable energy credits including the Prohibited Foreign Entity rules, the Prevailing Wage and Apprenticeship rules, the Direct Pay Election rules, the Transfer of Credit rules, the Domestic Content rules, and the “Beginning of Construction” rules.
• Advises clients involved in the areas of solar development (Sections 48 and 48E), BESS (battery energy storage system) projects, wind incentives, Advanced Manufacturing Production Credit (Section 45X), Advanced Manufacturing Investment Credit (Section 48D), hydrogen, energy communities, the low-income communities program, energy manufacturing credits, and home/building energy incentives.
• Advises clients on a wide range of manufacturing and infrastructure issues including bonus depreciation, the Qualified Production Property deduction, and cost recovery.
• Counsel to a state trade association on renewable energy for a year-long project of monthly webinars on the renewable energy provisions included in the Inflation Reduction Act
• Lead in-house company tax counsel on all US federal energy tax policy issues including renewable energy, upstream, downstream, and excise taxes for a leading Fortune 100 energy company

Business Tax

• Advises clients including for-profit and non-profit businesses on a broad range of employment tax issues related to remote working in the US and abroad; state tax issues for employers related to tax nexus, business registration, and remote workers; business expense and reimbursement issues; termination of employees; Social Security; and tax issues related to visas
• Counsel to national accounting firm related to all tax developments covering federal, state, and international issues in all tax subject areas providing tax content for monthly newsletters and periodic technical articles
• Advises clients on tax legislative and regulatory developments related to corporate and international tax rules for US-based companies and foreign-owned companies
• Advises clients in connection with COVID-19 stimulus programs including the Employee Retention Tax Credit, the paid sick and family leave tax credit, and tax issues related to the Paycheck Protection Program
• Established and managed US and foreign tax policy practice at a leading international law firm

Corporate In-House and Government Experience

• Lead in-house tax counsel for leading Fortune 100 energy company on all US federal corporate and international tax policy issues including both in-bound and out-bound issues covering strategy development through advocacy on the issues before Congress, the Treasury Department, and the IRS
• As Head of US & Global Tax Policy for a leading Fortune 100 energy company, established and managed internal Global Tax Policy Team, which coordinated tax policy issues worldwide and managed company work on the OECD Base Erosion and Profit Shifting (BEPS) project
• Served as Majority Tax Counsel to the House Ways & Means Committee covering several key tax laws including the Tax Reform Act of 1986 with responsibility for formulating revenue proposals; drafting legislation and Committee reports; briefing the Committee Chairman; other Committee members and the press on legislative proposals; and coordinating Committee hearings
• In-house company manager for a 4-year successful tax treaty project between the US and the UK