IRS Provides Relief for Offshore Wind and Federal Land Projects | McDermott Will & Emery
OVERVIEW New guidance from the Internal Revenue Service (IRS, the Service) extends the Continuity Safe Harbor to 10 years for both offshore wind projects and projects on federal land. IN DEPTH As background, eligibility for the production tax credit (PTC) under Section 45 and the investment tax credit (ITC) under Section 48 ties to the date when a project “begins construction.” There is extensive existing guidance from the Service regarding when a project is treated as having begun construction. Broadly speaking, a project is treated as having begun construction when it meets either the P...