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Notice 2020-88: Reallocations of section 48A credits under qualifying advanced coal project program

Notice 2020-88: Reallocations of section 48A credits

The IRS today released an advance version of Notice 2020-88 concerning a new round of (re)allocations of section 48A credits under the qualifying advanced coal project program.


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Previously, there were two rounds of allocations of the credits under the section 48A Phase III program—one in 2012 and the second in 2015.

According to Notice 2020-88 [PDF 117 KB], after the completion of the second round, the IRS and Treasury Department conducted a review and determined that $2,041,500,000 of section 48A credits are available for reallocation due to forfeitures of previously allocated section 48A credits or unallocated credits.

Notice 2020-88, therefore, announces the beginning of Round 3 of the section 48A Phase III program. To be considered in Round 3, applications must be submitted both to the Department of Energy (DOE) (Application for DOE Certification) and to the IRS (Application for Section 48A Certification) on or before 90 days after “date of publication.”

According to an IRS transmittal message, Notice 2020-88 is scheduled to be published in the Internal Revenue Bulletin on December 28, 2020.

Additional rules and other guidance items are provided in the IRS notice and in appendices to the notice.

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