Special Rules for Computing Investment Credit

Internal Revenue Service Department of the Treasury
Washington, DC 20224
Number: 201640010
Release Date: 9/30/2016
Index Number: 38.00-00, 50.00-00
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In Re: ---
Third Party Communication: None
Date of Communication: Not Applicable
Person To Contact:
---, ID No. ---
Telephone Number:
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Refer Reply To:
CC:PSI:5
PLR-117279-16
Date:
June 29, 2016
LEGEND:
Tribe = ---
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Dear ---:
As discussed in a telephone conversation with Taxpayer’s authorized representative, we are revoking Private Letter Ruling 201310001, dated December 5, 2012.
In Private Letter Ruling 201310001, the Internal Revenue Service concluded that
Tribe may elect to pass investment credits associated with the Renewable Energy
Assets to an unrelated third party lessee (Lessee) under § 50(d)(5).
After reconsideration, we have concluded that Tribe may not elect to pass investment credits associated with the Renewable Energy Assets to Lessee under § 50(d)(5). Accordingly, Private Letter Ruling 201310001 is revoked prospectively, and Tribe may place no further reliance on the ruling.
PLR-117279-16 2
In accordance with the power of attorney, we are sending a copy of this letter to
Tribe’s authorized representative. We are also sending a copy of this letter to the appropriate SB/SE office.
Enclosure:
Sincerely yours,
Theresa M. Melchiorre
Assistant to the Branch Chief, Branch 5
Office of Associate Chief Counsel
(Passthroughs and Special Industries)
Copy for 6110 purposes cc: