August 10, 2026

Milbank Advises Morgan Stanley on Tax Equity Financing in Connection with $1.7B Project Investment in Bloom Energy Fuel Cells for Nebius AI Infrastructure

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Milbank LLP advised Morgan Stanley, acting as sole tax equity investor and placement agent for a sale of tax credits, in connection with a $1.7 billion financing of the development and deployment by Industrial Development Funding of Bloom Energy's (NYSE: BE) fuel cell technology to support the build-out of Nebius's AI cloud infrastructure. 

Once complete, the project will provide dedicated behind-the-meter power, helping Nebius meet growing demand for the compute capacity underpinning its AI cloud platform. This innovative financing structure is expected to serve as a model for future development of on-site energy generation.

The Milbank team was led by Global Project, Energy and Infrastructure Finance partners Mike Duff, Christopher Bloom and Tax partner Drew Batkin. The team also included Global Project, Energy and Infrastructure Finance partner Jaime Ramirez, associates Jose Barragan-Monge, Anthony Lynch, Stephanie Batres and law clerk Peyton Lacoste.