Revenue Procedure 2007-65 provides that it, like most (if not all) safe harbors established by the IRS, is “not intended to provide substantive rules and are not to be used as audit guidelines.” Thus, while a Project Company that meets all of the requirements of the safe harbor will not be subject to challenge by the IRS, no negative presumption should be attached to a Project Company that fails to satisfy all of the requirements. Although Revenue Procedure 2007-65 is expressly made applicable only to wind projects, developers and investors often utilize the safe harbor set forth therein to structure investment in other types of renewable energy projects as well. In accordance with this intention, as long as the Project Company meets each of the safe harbor requirements of Revenue Procedure 2007-65, the IRS will respect the allocation of claimed credits. The revenue procedure was intended to provide needed certainty to wind developers and investors in light of the IRS’s “no rule” position established in Notice 2006-88 that the IRS will not issue private letter rulings addressing partnership issues arising in connection with the Section 45 production tax credit. However, it doesn't take long before Matt wins over Ophelia's heart as well.Background of Revenue Procedure 2007-65 In 2007, the Internal Revenue Service (IRS) released, which provides a safe harbor pursuant to which the IRS will respect the allocation to developers of and investors in a wind energy project by a partnership that owns and operates this project (a “Project Company”), of production tax credits arising under Section 45 of the Internal Revenue Code. Her mother worries about her friendship and suspects Matt of being a pedophile. While walking on the beach one day, Pip meets Matt, an artist with a broken heart. Her mother, Ophelia, has trouble dealing with the loss and becomes depressed. Pip was once a normal 11-year-old kid with a happy life, but she became very lonely when her father and brother died at a plane crash. Safe Harbour (also known as Danielle Steel's Safe Harbour) is a 2007 American direct-to-video romantic drama film directed by Bill Corcoran, based upon the 2003 novel of the same name by Danielle Steel.
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