SECTION 4. MASTER CONTRACT

.01 In general . Section 4.03(2) of Notice 2013–29, setting forth the Physical Work Test, provides:

If a taxpayer enters into a binding written contract for a specific number of components to be manufactured, constructed, or produced for the taxpayer by another person under a binding written contract (a “master contract”), and then through a new binding written contract (a “project contract”) the taxpayer assigns its rights to certain components to an affiliated special purpose vehicle that will own the

2013–44 I.R.B. 431 October 28, 2013

facility for which such property is to be used, work performed with respect to the master contract may be taken into account in determining when physical work of a significant nature begins with respect to the facility. .02 Master contract for Safe Harbor . The master contract provision, as described in section 4.03(2) of Notice 2013–29 under the Physical Work Test, also applies for purposes of the Safe Harbor.