The Internal Revenue Service issued Private Letter Ruling 201214007 April 6, concluding that where a taxpayer purchased wind energy facilities accompanied by facility-specific Power Purchase Agreements, no portion of the purchase price need be allocated to the PPAs as a separate asset. The result is favorable for acquirers of renewable energy facilities seeking to take advantage of accelerated depreciation deductions and the investment tax credit.
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Wind PPA tax rule
- Mintz Levin Cohn Ferris Glovsky and Popeo PC
- David Leiter, Sarah Litke and Daniel Phillips
- April 15 2012
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