IRS Revokes Earlier Ruling That Allowed Taxpayer to Include Facility-Specific PPAs in Wind Farms' Cost Basis

December 2012


On December 7, 2012, the Internal Revenue Service revoked an earlier private letter ruling allowing taxpayers to include the value of facility-specific power purchase agreements ("PPAs") for wind energy projects in the depreciable basis of the project. Taxpayers who may have included PPAs in cost basis should now consider how to best reconcile that position with the recent notice.

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