New Clean Renewable Energy Bonds (New CREBs) are one of several types of tax credit bonds authorized under IRC Section 54A, that allow a credit to investors that hold such bond on one or more of the quarterly credit allowance dates. New CREBs must comply with the requirements of IRC Section 54C.
May any qualified issuer, as defined in IRC section 54C(d)(6), apply for the unallocated portion of the New CREBs cooperative electric company volume cap allocation originally authorized under Announcement 2010-54 and Notice 2009-33 provides that qualified issuers awarded an allocation of New CREBs are allowed three years, from the date of the letter awarding such allocation, to issue their bonds. Does the same requirement apply to New CREBs allocations awarded pursuant to 2015-12?
Yes. The rules set forth in Notice 2009-33 would apply to applications submitted pursuant to Announcement 2010-54 and Announcement 2015-12. Qualified issuers awarded an allocation for a qualified project owned by a cooperative electric company will also have three years, from the date of the letter awarding such allocation, to issue their bonds.