On June 22, 2018, the IRS issued Notice 2018-59 (ITC Guidance), providing long-awaited guidance on the "begun construction" requirements for facilities qualifying for the Section 48 investment tax credit (ITC). The ITC is a...more
On December 15, 2016, the IRS issued Notice 2017-04, which clarifies and extends certain "begun construction" requirements for facilities qualifying for the Section 45 production tax credit (PTC) for which construction must...more
In the inaugural column of ‘‘Power and Taxes,’’ we discussed the tensions surrounding the requirement that an investor be an owner when a project is placed in service in order to qualify for the investment tax credit under...more
10/2/2016
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Complex Financial Products ,
Condition Precedent ,
Condition Subsequent ,
Investment Funds ,
Investment Partnerships ,
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Production Tax Credit ,
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Renewable Energy Incentives ,
Repurchases ,
Rescission ,
Tax Court
Following last year's extension of the investment tax credit for qualifying projects for which construction begins prior to January 1, 2020, and of the production tax credit (PTC) with respect to certain facilities the...more