Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

Section 54C.—New Clean Renewable Energy Bonds

A notice that solicits applications for allocations of the present total national bond volume limitation authority of $2.4 billion to issue new clean renewable energy bonds (New CREBs) under section 54C(a) of the Internal Revenue Code (the “Code”) to finance certain qualified projects described in section 45(d) of the Code and provides related guidance on the following: (1) eligibility requirements that a project must meet to be considered for a volume cap allocation; (2) application requirements and the application form for requests for volume cap allocations; (3) the method that the IRS will use to allocate the volume cap; and

(4) certain aspects of the applicable law and interim guidance in this area. See Notice 2009-33, page 865.

Section 1001.—Deter- mination of Amount and Recognition of Gain or Loss

26 CFR 1.1001–3: Modifications of debt instruments.

This revenue procedure describes the conditions under which changes to certain mortgage loans will not cause the Internal Revenue Service to challenge the tax status of certain securitization vehicles that hold the loans or to assert that those modifications

give rise to prohibited transactions. See Rev. Proc. 2009-23, page 884.

Section 7701.—Definitions

26 CFR 301.7701–4: Trusts.

This revenue procedure describes the conditions under which changes to certain mortgage loans will not cause the Internal Revenue Service to challenge the tax status of certain securitization vehicles that hold the loans or to assert that those modifications give rise to prohibited transactions. See Rev. Proc. 2009-23, page 884.

2009–17 I.R.B. 864 April 27, 2009