See Treas. Reg. §1.409A-2(a)(1). The Plan treats this election as not being subject to the timing rules applicable to payment elections.
See Treas. Reg. 1.409A-2(b)(2)(iv).
See Treas. Reg. §1.48-9(d)(6). Our discussions with the IRS national office have suggested that the same principle should be used for the cash grant program. The cash grant program is supposed to mimic the investment credit. See Joint Explanatory Statement of the Committee Conference, to ARRA, at pg. 115. Treasury has not stated whether it plans to adopt the 75% rule. There are other precedents the Treasury might apply to allow a full credit as long as the primary energy source is sunlight. The equipment that uses solely natural gas does not qualify for the cash grant. Equipment that uses solely solar energy exclusively does. The 75% rule is relevant for equipment that uses both. Cash Grant Opinion - Ivanpah 14 April 5, 2011 Gas used as a preheater for the Ivanpah projects provides heat that reduces the amount of heat a project needs to generate from solar energy. Thus, because gas is used to preheat the boiler may cause certain equipment that uses both solar and nonsolar energy to be disqualified in whole or in part from qualifying for the cash grant if the Treasury applies the 75% rule.
See Treas. Reg. . § 1.704-1(e)(2).
See Treas. Reg. § 1.6033–2(g)(1)(v) (a state institu tion exempt from taxation under § 501(a) the income of which is excluded from gross income under § 115(a) (now § 115(1)) is not required to file an annual information re turn on Form 990, Return of Organiza tion Exempt From Income Tax); see also Rev. Proc. 95–48, §§ 3.01, 4.02, 1995–2 C.B. 418.
See Treas. Reg. § 1.148-1(c)(4).
See Treas. Reg. § 1.148-3 for a detailed description of the computation of arbitrage rebate (including certain computation credits). In particular, certain formal elections and informal selections, applications and allocations may be made in connection with the computation of arbitrage rebate. Absent an applicable exception (such as that for certain Bona Fide Debt Service Funds as provided for in Section 148(f)(4)(A) and Treas. Reg. § 1.148-3(k)), arbitrage rebate with respect to the Bonds may need to be computed as to Nonpurpose Investments in the following funds or accounts: Debt Service Fund Costs of Issuance Fund Escrow Fund The first rebate installment payment must be made for a Computation Date that is not later than five years after the Issue Date. Each subsequent rebate installment payment must be made for a Computation Date that is not later than five years after the previous Computation Date for which an installment payment was made. The final rebate payment must be made for the final Computation Date. The final Computation Date with respect to an issue generally is the date the last outstanding bond of the issue is Discharged. For a fixed Yield issue, an Issuer may treat any date as a Computation Date. For a variable Yield issue, an Issuer:
See Treas. Reg. § 1.409A-2(b)(2)(iii) (2007). compensation plan should expressly provide that each annual payment is a separate payment.51
See Treas. Reg. § 1.446–1(e). This in- cludes issues that are or have been the sub- ject of a request by or with respect to the taxpayer for consent to change a method of accounting under procedures such as Rev. Proc. 97–27, 1997–1 C.B. 680 (as modified and amplified by Rev. Proc. 2002–19, 2002–1 C.B. 696, and as ampli- fied and clarified by Rev. Proc. 2002–54, 2002–2 C.B. 432), or its predecessor or successor, or of an application filed un- der automatic consent procedures such as Rev. Proc. 2002–9, 2002–1 C.B. 327 (as modified and clarified by Announcement 2002–17, 2002–1 C.B. 561, as modified and amplified by Rev. Proc. 2002–19, and as amplified, clarified, and modified by Rev. Proc. 2002–54), or its predecessor or successor. This also includes issues for which a change in accounting method is necessary to resolve the issue. A taxpayer must obtain consent to make an account- ing method change by using applicable administrative procedures. See generally Rev. Proc. 97–27 and Rev. Proc. 2002–9, or their successors;
See Treas. Reg. § 1.553-1 24 Code Section 553 was repealed as part of the American Jobs Creation Act of 2004. P.L. 108-357, § 413 (2004)./DIV> purposes of Code section 553.25
