In a memorandum released on June 12th, the IRS confirms that the safe harbor for Section 45 wind energy production tax credit (PTC) transactions set forth in Revenue Procedure 2007-65 does not apply to partners or partnerships with Section 48 energy credits, such as partnership flip transactions involving the solar investment tax credit (ITC).
This IRS memorandum, Chief Counsel Advice (CCA) 201524024, has generated a flurry of interest in the solar community. … More