SECTION 2. BACKGROUND — Internal Revenue Bulletin 2015-10

.01 Section 46 provides that the amount of the investment credit for any taxable year is the sum of the credits listed in § 46. That list includes the qualifying advanced coal project credit under § 48A.

.02 Section 48A(d)(1) provides that the Secretary, in consultation with the Secretary of Energy, shall establish a qualifying advanced coal project program for the deployment of advanced coal-based generation technologies. The Treasury Department and the Service established the § 48A Phase I program in Notice 2006– 24, 2006–1 C.B. 595, as modified and updated by Notice 2007–52, 2007–1 C.B. 1456. .03 Pursuant to § 48A(d)(3)(B)(i) and (ii), the § 48A Phase I program provided for (i) $800 million of credits to be allocated to integrated gasification combined cycle projects and (ii) $500 million of credits to other advanced coal projects. The Service allocated credits through an

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nual allocation rounds in 2006, 2007–08, and 2008–09, and a special allocation round in 2008.

.04 Pursuant to § 48A(d)(3)(B)(iii), the Treasury Department and the Service established the § 48A Phase II program by issuing Notice 2009–24, 2009–1 C.B. 817, to allocate an additional $1.25 billion of credits for advanced coal-based generation technology projects. The Service allocated credits through two allocation rounds in 2009–10 and 2011–12.

.05 Pursuant to § 48A(d)(4), the Treasury Department and the Service issued Notice 2012–51, 2012–2 C.B. 150, to establish the § 48A Phase III program to reallocate $658.5 million of Phase I credits. In Announcement 2013–43, 2013–2 C.B. 524, the Service announced that the total amount of $658.5 million of credits had been allocated, and accordingly, the 2012–13 allocation round would be the only allocation round in Phase III.

.06 The Service has since determined that $1,104,000,000 of § 48A credits are available for reallocation due to forfeitures of previously allocated Phase I and Phase II credits and unallocated Phase II credits. Accordingly, the Treasury Department and the Service have determined that an additional allocation round is appropriate, and this notice therefore begins Round 2 of the § 48A Phase III program.