This announcement discloses the results of the Phase III allocation round under the qualifying gasification project program of § 48B of the Internal Revenue Code. This announcement also serves as notice to applicants that no additional allocation rounds will be conducted under the qualifying gasification project program.
On December 29, 2014, the Internal Revenue Service (“Service”) published Notice 2014–81, 2014–53 I.R.B. 1001 (“the Notice”), to announce the beginning of the § 48B Phase III allocation round under the qualifying gasification project program (the “Phase III program”).
The Notice provides that the credit for a taxable year under the Phase III program is an amount equal to 20 percent of the qualified investment (as defined in § 48B(b)) for that taxable year in qualifying gasification projects (as defined in § 48B(c)(1)) for which the credit is allocated under § 48B(d)(1)(A).
Section 48A(d)(5) provides that the Secretary shall, upon making a certification under § 48B(d), publicly disclose the identity of the applicant and the amount of the credit certified with respect to such applicant. Section 9.01 of the Notice further provides that the Service intends to publish the results of Phase III allocation round, and disclose the following return information in the event the Phase III credit is allocated to the taxpayer’s project: (a) the name of the taxpayer and (b) the amount of the Phase III credit allocated to the project.
Accordingly, the results of the Phase III allocation round of the qualifying gasification program provided by § 48B are as follows:
| Program | Taxpayer | Credit Allocated | Total Credit Allocated |
| Phase III | Clean Energy Resources, LLC | $130,000,000 | |
| Lake Charles Resources, LLC | $130,000,000 | ||
| $260,000,000 |
Additionally, § 48B(d)(2) provides that certificates of eligibility for credit awardees may be issued under the § 48B program only during the 10-year period beginning on October 1, 2005. As a result, the Service may only reallocate as Phase III credits any available § 48B credits prior to October 1, 2015. Accordingly, the Service will not conduct additional allocations under Phase III of the qualifying gasification program.
The principal author of this announcement is Jennifer C. Bernardini of the Office of Associate Chief Counsel (Passthroughs & Special Industries). For further information regarding this announcement contact Jennifer C. Bernardini at (202) 317-5118 (not a toll-free number).
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