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IRS Guidance For Flip Structures In Wind Deals

Law360 (October 24, 2007, 12:00 AM EDT) -- On October 19, 2007, the IRS issued much anticipated guidance that provides clarity for investor transactions in wind energy projects that qualify for the section 45 tax credit for renewable energy production.

The Internal Revenue Code currently provides a tax credit of $20 per megawatt for electricity generated by wind projects that are placed in service before the end of 2008.

In order to finance wind projects, developers seek investors that can take advantage of the available tax credits. The predominant structure used with investors is...
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