Raghav Agnihotri | Frost Brown Todd

Raghav Agnihotri

Senior Associate

Cincinnati, OH

Office Phone Number 513.651.6755 Email
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Practices

Biography

Raghav is a senior associate in Frost Brown Todd’s Tax Practice Group, where he advises domestic and foreign clients on U.S. federal, international, and state and local tax matters.

He assists sponsors, developers, and investors in structuring and optimizing renewable energy and infrastructure projects, including those eligible for production and investment tax credits, carbon capture incentives, and other emerging technologies. Raghav regularly structures direct pay elections and credit transfers under § 6418, implements bonus credit strategies (domestic content, energy community, and low-income projects), and advises on compliance with prevailing wage and apprenticeship requirements under the Inflation Reduction Act of 2022 and the One Big Beautiful Bill Act. His work spans partnership and corporate structures, tax equity financings, project capital raises, joint ventures, and secondary-market credit sales.

Drawing on prior experience at both Big Four and middle-market accounting firms, Raghav also counsels clients on cross-border reorganizations, inbound and outbound M&A, repatriation planning, GILTI/FDII optimization, and OECD/§ 482 documentation. He frequently advises on choice-of-entity planning and corporate structures to facilitate efficient repatriation and minimize withholding tax through treaty-based planning.

Raghav also supports multistate businesses with economic nexus strategies, exposure to gross receipts and sales taxes, apportionment models, and performance-based incentive negotiations. He has extensive experience in voluntary disclosure agreements and audit defense across multiple jurisdictions.

Other Info About Raghav

Experience

Legal Work Highlights

Structured over $200 million in tax credit sales and transfers under IRC § 6418, including due diligence, drafting transfer agreements, coordinating IRS pre-approval requests, and ensuring compliance with elective transfer rules. Advised sponsors on liquidity solutions by pairing credit sales with tax equity flips and back-leverage financings.

Designed and executed direct pay registrations for tax-exempt sponsors and non-filers, securing millions in cash payments across solar, wind, and advanced manufacturing projects.

Counseled clients on timing and election mechanics to synchronize project placed-in-service dates with Treasury guidance, maximizing basis recovery.

Developed domestic content and energy community eligibility analyses for clean energy portfolios, stacking low-income and brownfield bonus credit adders to increase credit value by up to 30%.

Drafted prevailing wage and apprenticeship compliance checklists and audit response playbooks following OBBBA updates, guiding clients through IRS self-certification procedures.

Prepared global tax memoranda for cross-border transactions, identifying treaty-based planning opportunities and quantifying permanent establishment exposure.

Designed repatriation and dividend planning strategies to optimize U.S. taxation of foreign earnings, leveraging GILTI high-tax exclusions and FDII rate differentials.

Drafted intercompany agreements documenting the arm’s-length nature of parent-subsidiary transactions in compliance with transfer pricing regulations.

Developed nexus and apportionment strategies for a regional manufacturing group, securing sales and use tax exemptions and negotiating property tax abatements.

Structured state R&D and investment tax incentives for technology and clean energy projects. Conducting state survey of marketplace‑facilitator and economic‑nexus thresholds for a digital‑platform client, developing a compliance roadmap that aligned collection mechanics with varying state laws.

Advised on Ohio’s Commercial Activity Tax assessment, negotiating with state authorities to limit exposure and secure a significant reduction in proposed liability.