SECTION 1. PURPOSE

This notice clarifies and modifies the prior notices ¹ published by the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) that address the beginning of construction requirement for qualified facility and energy property projects under §§ 45 and 48, respectively, of the Internal Revenue Code (Code). Specifically, section 4.01 of this notice provides that a qualified facility or energy property construction project that is an Offshore Project or a Federal Land Project (each as defined in section 4.02 of this notice) satisfies the Continuity Safe Harbor (as defined in section 2.04(3) of this notice) if a taxpayer places the qualified facility or energy property that is the subject of the project into service within 10 calendar years after the calendar year during which construction of the project began.