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IRS Notice Clarifies Beginning-of-Construction Safe Harbor for ITC, PTC

Thursday, December 15, 2016 - 12:15PM

The Internal Revenue Service (IRS) today issued Notice 2017-04 to clarify beginning-of-construction guidance for renewable energy investment tax credit (ITC) and production tax credit (PTC) properties. The notice specifies that a taxpayer satisfies the continuity safe harbor provisions by placing a facility in service by the later of the calendar year no more than four calendar years after the year during which construction began or Dec. 31, 2018. The notice also prohibits the combination of methods to satisfy the beginning-of-construction requirement and clarifies what property costs can be included to satisfy the 80-20 rule for the five percent safe harbor for retrofitted facilities.

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