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IRS RULING EXCLUDES PPAs FROM WIND PURCHASE PRICE ALLOCATION

Monday, April 9, 2012 - 7:00AM

Power purchase agreements (PPAs) are excluded from the purchase price allocation on wind transactions, according to Private Letter Ruling (PLR) 201214007 issued Friday by the Internal Revenue Service (IRS). The ruling could have significance to outright project purchases, project purchases via the sale leaseback structure, midstream purchases and other PPA arrangements. The ruling was directed to the taxpayer who requested it and may not be used or cited as precedent, according to the IRS.

If you would like more information about PLR 201214007 and what it could mean for your project, please contact Stephen Tracy at (415) 356-8000 or at [email protected].

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