IRS Rules That Facility-Specific PPAs for Wind Farms Are Part of Facility Cost Basis

April 2012


On April 6, 2012, the Internal Revenue Service released a private letter ruling, PLR 201214007, in which it determined that facility-specific power purchase agreements ("PPAs") for wind energy facilities are not treated as depreciable assets separate from the facilities themselves. Any value created by such a PPA is includable in the adjusted depreciable basis of the facility to which it is related.

Return to Tax research and insights 
Alternative & Renewable Energy Tax Newsalert archive

Contact us

Matthew Haskins
US Sustainable Business Solutions tax leader
Tel: +1 (202) 414 1570

Stuart Finkel
Tel: +1 (646) 471 0616

Courtney Sandifer

Follow us