
Like governmental entities, certain 501(c)3s are permitted to issue
tax-exempt debt. Because interest earnings are not subject to federal
taxes, tax-exempt bonds are issued with relatively low coupon rates
producing significantly lower capital costs than taxable issues. To
match the power purchase agreement and turbine useful life, the
amortization for a tax-exempt financing would be between 15 and
20 years. Similar to a taxable variable rate issue, a letter of
credit from a credit worthy commercial bank may be used provide
credit enhancement. With a standard tax-exempt issue, the
developer would not be eligible to receive production tax
credits. However, it is possible to utilize a "flip" structure
where taxable bonds are issued to enable the equity investor,
who will have 99% ownership, to receive PTC and accelerated
depreciation benefits. At year ten, there it is possible to
flip ownership to the non-profit. The non-profit will assume
99% ownership and the project could be refinanced using
tax-exempt bonds. This ownership offers the benefits of the
tax benefits associated with renewable energy projects and the
benefits of low cost tax-exempt financing.
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