Professional Tax Research Solutions from the Founder of Kleinrock. tax research
Parker Tax Pro Library
Accounting News Tax Analysts professional tax research software Like us on Facebook Follow us on Twitter View our profile on LinkedIn Find us on Pinterest
CPA software
Professional Tax Software
tax and accounting
Tax Research Articles Tax Research Parker's Tax Research Articles Accounting Research CPA Client Letters Tax Research Software Client Testimonials Tax Research Software tax research


Accounting Software for Accountants, CPA, Bookeepers, and Enrolled Agents

CPA Tax Software

        

 

IRS: Reflective Roof Installed in Connection with Solar Panels Qualifies for Energy Credit. (Parker Tax Publishing December 26, 2014)

The IRS ruled that a reflective roof, when installed in connection with a bifacial paneled solar power system, constituted energy property under Code Sec. 48 to the extent that the cost of the reflective roofing exceeded the cost of reroofing the Taxpayer's building with a non-reflective roof. PLR 201450013 (12/12/14).

Background

Taxpayer, a privately held limited liability company, considered purchasing a rooftop solar photovoltaic generation system (the system) to help defray energy costs. The system included bifacial panels, able to generate electrical energy using not only direct sunlight that strikes the panels from above, but also sunlight that is reflected from the surface on which the panels are installed. It was recommended that the panels be installed over highly reflective roof membranes in order to generate a significant amount of electrical energy through reflected sunlight.

In connection with the installation of the solar panel system, Taxpayer anticipated installing a reflective membrane over the portion of the roof located beneath the system and requested a ruling that the reflective roof, when installed in connection with the system, constitutes energy property under Code Sec. 48.

Analysis

Code Sec. 48(a)(3)(A)(i) provides that energy property includes any equipment which uses solar energy to generate electricity.

Reg. Sec. 1.48-9(d)(1) provides that energy property includes solar energy property, however, Reg. Sec. 1.48-9(d)(2) specifically excludes from qualification as energy property "passive solar systems" based on the use of conductive, convective, or radiant energy transfer. Reg. Sec. 1.48-9(d)(3) provides, in part, that solar energy property includes equipment that uses solar energy to generate electricity, and includes storage devices, power conditioning equipment, transfer equipment, and parts related to the functioning of those items.

The IRS stated that the reflective roof satisfies the definition of energy property under Reg. Secs. 1.48-9(d)(1) and 1.48-9(d)(3) when installed in connection with the system. Because the unique double-sided panels generate electricity using sunlight reflected from the surface on which the panels rest, the reflective roof helped enable the system to generate significant amounts of electricity, and was part of the equipment and materials using solar energy to directly generate electricity. Thus the IRS ruled it constituted energy property under Code Sec. 48 to the extent that the cost of the reflective roofing exceeded the cost of reroofing the Taxpayer's building with a non-reflective roof.

For a discussion of energy credits, see Parker Tax ¶104,315 (Staff Editor Parker Tax Publishing)

Disclaimer: This publication does not, and is not intended to, provide legal, tax or accounting advice, and readers should consult their tax advisors concerning the application of tax laws to their particular situations. This analysis is not tax advice and is not intended or written to be used, and cannot be used, for purposes of avoiding tax penalties that may be imposed on any taxpayer. The information contained herein is general in nature and based on authorities that are subject to change. Parker Tax Publishing guarantees neither the accuracy nor completeness of any information and is not responsible for any errors or omissions, or for results obtained by others as a result of reliance upon such information. Parker Tax Publishing assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect information contained herein.

Parker Tax Pro Library - An Affordable Professional Tax Research Solution. www.parkertaxpublishing.com


Professional tax research

We hope you find our professional tax research articles comprehensive and informative. Parker Tax Pro Library gives you unlimited online access all of our past Biweekly Tax Bulletins, 22 volumes of expert analysis, 250 Client Letters, Bob Jennings Practice Aids, time saving election statements and our comprehensive, fully updated primary source library.

Parker Tax Research

Try Our Easy, Powerful Search Engine

A Professional Tax Research Solution that gives you instant access to 22 volumes of expert analysis and 185,000 authoritative source documents. But having access won’t help if you can’t quickly and easily find the materials that answer your questions. That’s where Parker’s search engine – and it’s uncanny knack for finding the right documents – comes into play

Things that take half a dozen steps in other products take two steps in ours. Search results come up instantly and browsing them is a cinch. So is linking from Parker’s analysis to practice aids and cited primary source documents. Parker’s powerful, user-friendly search engine ensures that you quickly find what you need every time you visit Our Tax Research Library.

Parker Tax Research Library

Dear Tax Professional,

My name is James Levey, and a few years back I founded a company named Kleinrock Publishing. I started Kleinrock out of frustration with the prohibitively high prices and difficult search engines of BNA, CCH, and RIA tax research products ... kind of reminiscent of the situation practitioners face today.

Now that Kleinrock has disappeared into CCH, prices are soaring again and ease-of-use has fallen by the wayside. The needs of smaller firms and sole practitioners are simply not being met.

To address the problem, I’ve partnered with a group of highly talented tax writers to create Parker Tax Publishing ... a company dedicated to the idea that comprehensive, authoritative tax information service can be both easy-to-use and highly affordable.

Our product, the Parker Tax Pro Library, is breathtaking in its scope. Check out the contents listing to the left to get a sense of all the valuable material you'll have access to when you subscribe.

Or better yet, take a minute to sign yourself up for a free trial, so you can experience first-hand just how easy it is to get results with the Pro Library!

Sincerely,

James Levey

Parker Tax Pro Library - An Affordable Professional Tax Research Solution. www.parkertaxpublishing.com

    ®2012-2017 Parker Tax Publishing. Use of content subject to Website Terms and Conditions.

IRS Codes and Regs
Tax Court Cases IRS guidance