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IRS Issues Revised Guidance for Wind-Energy Partnerships by David S. Lowman
Hunton & Williams LLP - Washington Office
Laura Ellen Jones
Hunton & Williams LLP - Richmond Office
Timothy L. Jacobs
Hunton & Williams LLP - Washington Office
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September 24, 2009
Previously published on September 2009
On September 21, 2009, the Internal Revenue Service (the "Service") issued Announcement 2009-69 (the "Announcement"), revising its prior guidance on wind-energy partnerships, Revenue Procedure 2007-65 (the "Revenue Procedure"). The Revenue Procedure sets forth the safe-harbor requirements for partnership flip structures involving wind energy projects qualifying for tax credits under Section 45 of the Internal Revenue Code (the "Code").
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