August.11.2014
On August 8, 2014, the IRS released Notice 2014-46, which provides additional guidance on the "start of construction" requirements for the investment tax credit (ITC) and production tax credit (PTC). As discussed in this alert, Notice 2014-46 provides additional guidance on satisfying the physical work test, the effect of transfers of a facility after construction has begun, and also modifies the five percent safe harbor.