PTC Update: IRS Plans to Release Guidance on Applying the “Begun Construction” Test

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According to Tax Notes Today, the IRS discussed its plans to release guidance on applying the “begun construction” test for the production tax credit (“PTC”) at the American Bar Association Section of Taxation meeting in Orlando, Florida last week. As reported in our January 2, 2013 blog post, this was one of the changes made to the renewable energy tax credit provisions by the American Taxpayer Relief Act of 2012. The guidance is expected to provide parameters that taxpayers can rely on, while considering administrative burdens on the IRS and burdens on taxpayers. The IRS recognizes this is an important issue and that there is a need for answers as soon as possible.