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Depending on the particular forms of subsidy (such as state tax credits, state cash subsidy payments, or solar carve-outs in state renewable portfolio standards designating the amount of generation local utilities must derive from renewable sources by certain benchmarks), the project owner may have more or less interest in actually owning the facility after the tax credit recapture and direct subsidy period has ended (though there are other tax considerations relating to the “profit motive” test that may require the project owner/seller to maintain longer-term ownership of the installation).
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owner: facfour - (no access) - The Law of Solar- A Guide to Business and Legal Issues.PDF.pdf, p17


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