IRS Updates Beginning of Construction Guidance
The Internal Revenue Service (IRS) today issued a notice to update beginning of construction guidance for the renewable energy production tax credit (PTC) or investment tax credit (ITC). Notice 2015-25 provides that if a facility is placed in service before Jan. 1, 2016, the facility will be considered to satisfy the continuous construction test for purposes of satisfying the physical work test, or the continuous efforts test for purposes of satisfying the safe harbor. If a taxpayer begins construction on a facility before Jan. 1, 2015 and places it in service before Jan. 1, 2017, Notice 2015-25 says the facility will be considered to satisfy the continuous construction test or the continuous efforts test, regardless of the amount of physical work performed or the amount of costs paid or incurred within that time frame.
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