Community Wind Toolbox Chapter 12: The Minnesota Flip Business Model
The Minnesota Flip business model was developed in response to a unique combination of federal incentives for wind development and state policies that encouraged development of community-owned wind projects. The structure has proven a successful model for landowners and equity investors interested in partnering in the development of wind projects. This partnership allows the equity investor to take advantage of federal tax credits, while providing local owners the economic benefits of ownership.
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IRS bulletin 2007-45 (skip to page 967) provides a summary of IRS Rev Proc 2007-65 which establishes a safe harbor for the allocation of tax credits for wind projects that use a flip business structure.

