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Introduction

SECTION 1. QUALIFYING

Internal Revenue Bulletin 2016-39 · 2026-10-03 edition · updated 2026-10-04 · United States

ADVANCED COAL PROJECT PROGRAM

Pursuant to § 48A(d)(4), on August 13, 2012, the Internal Revenue Service (the “Service”) published Notice 2012–51, 2012–2 C.B. 150 (the “Notice”) to establish the § 48A Phase III qualifying advanced coal project program (the “Phase III program”) to allocate § 48A credits (the “Phase III credits”).

The Notice provides that the credit for a taxable year under the Phase III program is an amount equal to 30 percent of the qualified investment for that taxable year in a qualifying advanced coal project that uses integrated gasification combined cycle technology or other advanced coalbased generation technology. To receive an allocation of the Phase III credits, a qualifying advanced coal project must in

clude equipment that separates and sequesters at least 70 percent of such project’s total carbon dioxide emissions.

Section 48A(d)(5) provides that the Secretary shall, upon making a certification under § § 48A(d) or 48B(d), publicly disclose the identity of the applicant and the amount of the credit certified with respect to such applicant. Section 10.01 of the Notice further provides that the Service intends to publish the results of the Phase III allocation round, and disclose the following information in the event the Phase III credit is allocated to the taxpayer’s project: (a) the name of the taxpayer and (b) the amount of the Phase III credit allocated to the project.

Accordingly, the certification resulting from the 2012–2013 Phase III allocation round of the qualifying advanced coal project program provided by § 48A is as follows:

Program Taxpayer Amount of Credit Certified

Phase III STCE Holdings, LLC $324,000,000

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