David Villagrana
Lead Counsel Clean Energy Tax Solutions
Work
Areas of expertise:
Federal Tax Law, Clean Energy Tax Incentives, Tax Controversy and Litigation
Description
As a federal tax attorney at EDF, David advances clean energy development through tax-centered litigation and policy advocacy. His work emphasizes incentives that support sustainable electric power generation, clean fuel production, electric vehicle deployment and infrastructure, carbon capture and sequestration, and domestic clean energy manufacturing. He furthers these efforts through legal actions in federal district court, administrative advocacy before the U.S. Department of the Treasury and IRS, in-depth legal analysis, policy development, and coalition engagement. David also advises cross-functional teams within EDF on initiatives that intersect with federal tax law and regulatory frameworks, helping translate complex tax provisions into actionable strategies.
Background
David is a federal tax attorney with extensive experience in drafting regulations and administrative guidance to implement clean energy tax incentives under federal law. At the IRS Office of Chief Counsel, he served as a drafter and advisor on rulemakings and notices such as the proposed regulations for I.R.C. § 45W, the domestic content bonus credits, and the elective payment guidance, working closely with colleagues at the U.S. Department of the Treasury and the U.S. Department of Energy to align technical tax rules with energy policy objectives. His background also includes significant litigation and enforcement experience within the IRS Office of Chief Counsel and the U.S. Department of Justice, giving him a practical perspective on how clean energy tax rules operate in real-world disputes and compliance settings.
Education
Juris Doctor, The George Washington University Law School, Washington, D.C.
M.A. Legislative Affairs, The George Washington University Graduate School of Political Management, Washington, D.C.
B.A. Political Science & History, University of Colorado at Denver, Denver, CO