Coordination With Section 142 Bond Financing

For facilities or equipment placed in service before 2023 and obligations issued after 2021, the credit for any project for any tax year is reduced by the amount that’s the product of the credit for such tax year and the lesser of 50% or a fraction, the numerator of which is the sum, for the tax year and all prior tax years, of the proceeds from an issue described in section 142(a)(17) used to provide financing for the project the interest on which is exempt from tax under section 103, and the denominator of which is the aggregate amount of additions to the capital account for the project for the tax year and all prior tax years. The amounts under the preceding sentence for any tax year are determined as of the close of the tax year.

Note: For purposes of the above, there are no prior tax years before January 1, 2022.