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Federal Tax Developments from Daily Tax Report ®



IRS PLR: NUCLEAR PLANT DECOMMISSIONING TRUST AGREEMENTS WON’T BE DISQUALIFIED
AFTER CHANGES IN FACILITY UNIT LEASED INTERESTS (IRC §468A)


Feb. 25, 2022, 5:00 AM
Bloomberg Law News 2022-02-28T09:53:36505-05:00


IRS PLR: NUCLEAR PLANT DECOMMISSIONING TRUST AGREEMENTS WON’T BE DISQUALIFIED
AFTER CHANGES IN FACILITY UNIT LEASED INTERESTS (IRC §468A)

2022-02-25T00:00:00000-05:00


A public utility’s retention of nuclear decommissioning trust agreements
relating to two units of a nuclear-powered electrical energy generating station,
after termination of certain leases and partial reduction of its qualifying
interests in the units, will not cause disqualification of any portion of either
agreement under Treas. Reg. §1.468A-5(c) regarding deduction of decommissioning
reserve fund payments, the IRS ruled. Under terms of a decommissioning agreement
(subject to commission approval and IRS favorable ruling) with the purchaser of
the leased interests, Taxpayer will maintain the trusts and balances therein in
accordance with all applicable laws until the decommissioning is complete. [PLR
202208002]

Reference:
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DOCUMENTS

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TOPICS

 * taxes paid deduction
 * tax accounting
 * accounting for income tax
 * nuclear decommissioning costs
 * nuclear energy
 * leasing
 * federal tax
 * public utilities


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