IRS Written Determinations
Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.
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PLR 200707097: Government hydropower project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a hydropower facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more…
PLR 200707096: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707095: One hydropower project receives bond allocation and three are denied
An issuer applied for Clean Renewable Energy Bond authority for four hydropower projects. The IRS approved a redacted allocation for the project in Appendix A under IRC § 54. It denied the three…
PLR 200707094: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707093: Two government hydropower projects denied bond allocations after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for two hydropower facilities owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no…
PLR 200707092: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707091: Solar project receives clean renewable energy bond allocation
An issuer applied for authority to finance a solar energy facility with Clean Renewable Energy Bonds. The IRS determined that the project qualified under IRC § 54, would have qualified ownership,…
PLR 200707090: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707089: Wind project receives bond allocation while landfill-gas and wind projects are denied
An issuer sought Clean Renewable Energy Bond authority for wind and landfill-gas facilities. The IRS approved a redacted allocation for the wind project in Appendix A under IRC § 54. It denied the…
PLR 200707088: Government landfill-gas project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a landfill-gas facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no…
PLR 200707087: Government trash-combustion project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a trash-combustion facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with…
PLR 200707086: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707085: Two government biomass projects denied bond allocations after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for two open-loop biomass facilities owned by governmental borrowers. IRC § 54 limited the overall allocations to $800 million,…
PLR 200707084: Government trash-combustion project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a trash-combustion facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with…
PLR 200707083: Government hydropower and wind projects denied bond allocations after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a hydropower facility and a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800…
PLR 200707082: Twelve wind projects receive clean renewable energy bond allocations
An issuer applied for authority to finance twelve wind facilities with Clean Renewable Energy Bonds. The IRS determined that the projects qualified under IRC § 54, would have qualified ownership,…
PLR 200707081: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707080: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707079: Government hydropower project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a hydropower facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more…
PLR 200707078: Two solar projects and a wind project receive allocations while another solar project is denied
An issuer sought Clean Renewable Energy Bond authority for solar and wind facilities. The IRS approved allocations for two solar projects and one wind project in Appendix A under IRC § 54. It denied…
PLR 200707077: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707076: Twelve solar projects receive clean renewable energy bond allocations
An issuer applied for authority to finance twelve solar energy facilities with Clean Renewable Energy Bonds. The IRS determined that the projects qualified under IRC § 54, would have qualified…
PLR 200707075: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707074: Government hydropower and wind projects denied bond allocations after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a hydropower facility and a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800…
PLR 200707073: Government hydropower project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a hydropower facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more…
PLR 200707072: Solar project receives clean renewable energy bond allocation
An issuer applied for authority to finance a solar energy facility with Clean Renewable Energy Bonds. The IRS determined that the project qualified under IRC § 54, would have qualified ownership,…
PLR 200707071: Government hydropower project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a hydropower facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more…
PLR 200707070: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707069: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707068: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707067: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707066: Ten government solar projects denied bond allocations after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for ten solar energy facilities owned by governmental borrowers. IRC § 54 limited the overall allocations to $800 million, with no…
PLR 200707065: Wind project denied bond allocation after total funding limit is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility. IRC § 54 limited the total allocation authority to $800 million and capped the governmental portion at $500…
PLR 200707064: Government trash-combustion project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a trash-combustion facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with…
PLR 200707063: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707062: Ten solar and ten biomass projects receive clean renewable energy bond allocations
An issuer applied for authority to finance ten solar energy facilities and ten open-loop biomass facilities with Clean Renewable Energy Bonds. The IRS determined that the 20 projects qualified under…
PLR 200707061: Three wind projects receive clean renewable energy bond allocations
An issuer applied for authority to finance three wind facilities with Clean Renewable Energy Bonds. The IRS determined that the projects qualified under IRC § 54, would have qualified ownership, and…
PLR 200707060: Two wind projects receive bond allocations and four projects fail to establish eligibility
An issuer sought Clean Renewable Energy Bond authority for wind, biomass, and solar facilities. The IRS approved allocations for the two wind projects in Appendix A under IRC § 54. It denied the…
PLR 200707059: Refined-coal production project receives clean renewable energy bond allocation
An issuer applied for authority to finance a refined-coal production facility with Clean Renewable Energy Bonds. The IRS determined that the project qualified under IRC § 54, would have qualified…
PLR 200707058: Government hydropower project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a hydropower facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more…
PLR 200707057: Two solar projects denied bond allocations for failure to establish eligibility
An applicant sought authority to issue Clean Renewable Energy Bonds for two solar energy facilities. The IRS denied allocations for both projects because the application did not demonstrate that one…
PLR 200707056: Government landfill-gas project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a landfill-gas facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no…
PLR 200707055: Government biomass project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for an open-loop biomass facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with…
PLR 200707054: Government biomass project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for an open-loop biomass facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with…
PLR 200707053: Wind project receives bond allocation while a solar project is denied
An issuer sought Clean Renewable Energy Bond authority for wind and solar facilities. The IRS approved a redacted allocation for the wind project in Appendix A under IRC § 54. It denied the…
PLR 200707052: Issuer receives clean renewable energy bond allocation with project details absent from appendix
An issuer applied for authority to finance a project with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership, and…
PLR 200707051: Five solar projects receive clean renewable energy bond allocations
An issuer applied for authority to finance five solar energy facilities with Clean Renewable Energy Bonds. The IRS determined that the projects qualified under IRC § 54, would have qualified…
PLR 200707050: Three solar projects receive clean renewable energy bond allocations
An issuer applied for authority to finance three solar energy facilities with Clean Renewable Energy Bonds. The IRS determined that the projects qualified under IRC § 54, would have qualified…
PLR 200707049: Two landfill-gas projects receive bond allocations while a solar project is denied
An issuer sought Clean Renewable Energy Bond authority for landfill-gas and solar facilities. The IRS approved allocations for the two landfill-gas projects in Appendix A under IRC § 54. It denied…
PLR 200707048: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707047: Two solar projects receive bond allocations while a biomass project is denied
An issuer sought Clean Renewable Energy Bond authority for solar and open-loop biomass facilities. The IRS approved allocations for the two solar projects in Appendix A under IRC § 54. It denied the…
PLR 200707046: Three solar projects receive clean renewable energy bond allocations
An issuer applied for authority to finance three solar energy facilities with Clean Renewable Energy Bonds. The IRS determined that the projects qualified under IRC § 54, would have qualified…
PLR 200707045: Six solar projects receive clean renewable energy bond allocations
An issuer applied for authority to finance six solar energy facilities with Clean Renewable Energy Bonds. The IRS determined that the projects qualified under IRC § 54, would have qualified…
PLR 200707044: Seven solar projects receive bond allocations and one is denied
An issuer sought Clean Renewable Energy Bond authority for solar energy projects. The IRS approved allocations for the seven projects in Appendix A under IRC § 54. It denied the governmental project…
PLR 200707043: Eleven solar projects receive bond allocations and two are denied
An issuer sought Clean Renewable Energy Bond authority for solar energy projects. The IRS approved allocations for the eleven projects in Appendix A under IRC § 54. It denied the two governmental…
PLR 200707042: Five solar projects receive bond allocations and one is denied
An issuer sought Clean Renewable Energy Bond authority for solar energy projects. The IRS approved allocations for the five projects in Appendix A under IRC § 54. It denied the governmental project…
PLR 200707041: Solar project receives clean renewable energy bond allocation
An issuer applied for authority to finance a solar energy facility with Clean Renewable Energy Bonds. The IRS determined that the project qualified under IRC § 54, would have qualified ownership,…
PLR 200707040: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707039: Government hydropower project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a hydropower facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more…
PLR 200707038: Government landfill gas project denied bond allocation after funding cap is reached
An applicant requested authority to issue Clean Renewable Energy Bonds for a landfill gas facility owned by a governmental borrower. IRC § 54 limited total allocations to $800 million and…
What these documents are
- Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
- Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
- Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
- Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
- Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.