IRS Clarifies Renewable Energy Tax Credit Safe Harbor

Monday, June 15, 2015 - 7:00am

The Internal Revenue Service (IRS) last week issued Chief Counsel Advice Memorandum 201524024, which said that a partnership allocating Section 48 renewable energy investment tax credits (ITCs) among its partners cannot rely on the Rev. Proc. 2007-65 safe harbor.  The memorandum states that Rev. Proc. 2007-65 provides a safe harbor only for partners or partnerships with Section 45 wind energy production tax credits (PTCs).