In two identical private letter rulings, LTR 201550024 and LTR 201550023, which were made public on December 11, the IRS granted a lessor in an inverted lease permission to make a late election to pass through to the lessee the 30 percent investment tax credit (ITC) under section 48. The IRS issued a third ruling, LTR 201552004, for a similarly structured transaction, permitting a late election out of bonus depreciation.
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