Tax Equity Financing means a transaction or series of transactions involving one or more investors seeking a return that is enhanced by Tax credits and/or Tax depreciation (each a “Tax Equity Investor”) and generally (i) described in Revenue Procedures 2001-28 (sale-leaseback (with or without “leverage”)), 2007-65 (flip partnership) or 2014-12 (flip partnership and master tenant partnership) as those revenue procedures are reasonably applied or analogized to a storage project transaction (as opposed to a wind farm or rehabilitated real estate) or
Tax Equity Financing means a tax equity financing entered into solely in connection with the acquisition, expansion, upgrade or refurbishment (or refinancing of any of the foregoing or of any Indebtedness incurred in connection therewith) of or by a Project Subsidiary (and/or another Subsidiary that is a direct or indirect parent company of such Project Subsidiary) of energy generating, transmission or distribution assets, or of any other energy or power facility or any assets related to any of the foregoing that are eligible for renewable energy production tax credits available under Section 45 of the Code or renewable energy investment tax credits available under Section 48 of the Code, as applicable, on an arm’s length basis.
Tax Equity Financing means a transaction or series of transactions involving one or more investors seeking a return that is enhanced by tax credits and/or tax depreciation and generally (i) described in Revenue Procedures 2001-28 (sale-leaseback (with or without “leverage”)), 2007-65 (flip partnership) or 2014-12 (flip partnership and master tenant partnership) as those revenue procedures are reasonably applied or analogized to an energy storage project transaction (as opposed to a wind farm or rehabilitated real estate) or (ii) contemplated by Section 50(d)(5) of the Internal Revenue Code of 1986, as amended (a pass-through lease).
Examples of Tax Equity Financing in a sentence
Normal Domestic Strength Wastewater shall mean wastewater with concentrations of CBOD, Suspended Solid, Total Kjeldahl Nitrogen and Total Phosphorus greater than 200, 250, 40, and 10 milligrams per liter (mg/I) respectively.
However, APEC should welcome timely opportunities to understand developments in the ACTA negotiations and how they can contribute to broadening the opportunities inherent in the Information Society.
Congressional Research Service, Tax Equity Financing: An Introduction and Policy Considerations, report number R45693, April 17, 2019.
For a discussion of the tax consequences of choosing to structure the initial investment by the tax equity investor as a contribution to the partnership or as a pur- chase and sale transaction, see Dennis Mortiz, Modeling Choices Impact Tax Equity Financing, N.
Seller shall provide Buyer with at least ninety (90) days’ prior written notice of the anticipated closing date of a Tax Equity Financing.
More Definitions of Tax Equity Financing
Tax Equity Financing means a transaction or series of transactions involving one or more investors seeking a return that is enhanced by tax credits and/or tax depreciation (each a “Tax Equity Investor”) and generally (a) described in Revenue Procedures 2001-28 (sale leaseback (with or without “leverage”)), 2007-65 (flip partnership) or 2014-12 (flip partnership and master tenant partnership) as those revenue procedures are reasonably applied or analogized to a solar project transaction (as opposed to a wind farm or rehabilitated real estate) or (b) contemplated by Section 50(d)(5) of the Code, as amended (a pass-through lease).
Tax Equity Financing means (a) in the case of First Solar, those transactions described in Part A of Schedule II, and (b) in the case of SunPower, those transactions described in Part B of Schedule II.
Tax Equity Financing means a transaction or a series of transactions in which a Person or Persons (i) invests in Seller or in a Project Company or any Upstream Equity Owner or Downstream Equity Owner, (ii) purchases a Facility and leases it back to Seller (or an Affiliate of Seller) or (iii) leases a Facility from Seller or an Affiliate of Seller or invests in a direct or indirect lessee of a Facility, in each case seeking to earn its economic return, in whole or in part, through tax benefits related to the ownership or operation of such Facility.
Tax Equity Financing means those transactions described in Schedule 1.1(d) of the AssetCo Disclosure Schedule.
Tax Equity Financing means (a) in the case of First Solar, those transactions described in Schedule 1.1(f) of the FS Disclosure Schedule, and (b) in the case of SunPower, those transactions described in Schedule 1.1(f) of the SP Disclosure Schedule.
Tax Equity Financing means a tax equity financing entered into solely in connection with the acquisition or refinancing by the Company or any of its Subsidiaries of energy generating, transmission or distribution assets (and any assets related thereto).
Tax Equity Financing means, with respect to each of the Projects, the transactions contemplated by the applicable Project Financing Documents.