Ambridge Partners Introduces Interconnection Tax Insurance Policy
4/8/2003
(New York, April 8, 2003) Ambridge Partners LLC (“Ambridge”) today introduced its Interconnection Tax Insurance policy designed to address uncertainty relating to the tax-free nature of certain payments made by independent power producers to owners of electrical transmission grids in connection with the construction of interconnection facilities. “This new policy provides a cost-efficient alternative to some of the traditional methods used by parties to these agreements to address this uncertainty such as an increase of the payment by an amount equal to the tax or a 'gross-up', or the posting of other security by the independent power producer in the event that the payments are deemed taxable,” said Jeffrey D. Cowhey, Ambridge’s President.
An Interconnection is the physical facility(ies) required to connect a power plant to a transmission grid. These facilities are constructed pursuant to interconnection agreements. Despite the safe harbors provided under various IRS notices and taxpayer-specific guidance provided pursuant to private letter rulings, most transmission grid owners are reluctant to absorb the risk that a payment made to construct an Interconnection will be tax-free.
For more information about the tax issue to which the product is designed to respond, policy forms, applications or broker informational packets, please contact Ambridge at 212.871.5400 or email us at info@ambridgepartners.com.
|