Document mmV4bDgwXeoeVy2GD4gN0wgxO

Message From: Sent: To: Subject: Troutman Sanders LLP [Communications@troutman.com] 6/25/2018 8:32:40 PM Wehrum, Bill [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=33d96ae800cf43a3911d94a7130b6c41-Wehrum, Wil] IRS Issues Beginning of Construction Guidance for Solar Click Here to view ooilOs. IRS Issues Beginning of Construction Guidance for Solar On June 22, 2018, the Internal Revenue Service (the "IRS") issued Notice 2016-59, which provides longawaited guidance on when construction of energy property will have begun for purposes of the Investment Tax Credit ("ITC") under section 48 of the Internal Revenue Code (the "Code"). The guidance is similar in many respects to the beginning of construction guidance issued for wind facilities and other facilities that are eligible for the PTC under section 45 of the Code or the ITC in lieu of the PTC (the "Prior Guidance"). Although the rules in Notice 2018-59 should be familiar to those who have worked with the Prior Guidance, this client alert covers the applicable rules in detail. Furthermore, this client alert will focus on solar PV projects, though Notice 2018-59 also applies to solar hot water, fiber-optic solar, geothermal, fuel cell, qualified microturbine, CHP, small wind, and geothermal heat pump property. At the end of this client alert, we provide a brief overview of the strategies for beginning construction on solar projects that we expect to be widely used. Quick Links IM ISY S e n e iiib te .Enemy Contacts SiaiiiKyne 202. 704.6150 E/mil M M iiioiloS; 503. 290.2321 Email Nohn.LeonN 949. 622.2769 iN M il EageLBssiM 404. 885.3516 Email I SUBSCRIBE Sierra Club v. EPA 18cv3472 NDCA Tiers 8&9 ED 002061 00181146-00001 f iff In Gl Troutman Sanders LLP. Advertising material. These materials are to Inform you of developments that may affect your business and are not to be considered legal advice, nor do they create a lawyer-client relationship. Information on previous case results does not guarantee a similar future result. Sierra Club v. EPA 18cv3472 NDCA Tiers 8&9 ED 002061 00181146-00002