NREL / SAM

System Advisor Model (SAM)
BSD 3-Clause "New" or "Revised" License
318 stars 136 forks source link

Create checkbox for whether or not to include loan fees in depreciation and ITC gross basis #1803

Open brtietz opened 1 week ago

brtietz commented 1 week ago

I'm tempted to remove the debt fees from the basis as well. Per https://www.irs.gov/pub/irs-drop/n-13-70.pdf (question 14) fees cannot be included in the basis. This is referring to the residential section of the code, and while I haven't found as strong of a reference for businesses (https://zenergyfin.com/solar-itc-table-eligible-and-ineligible-costs/ is the best to date), I haven't found anything that conflicts and says that they are allowed. It seems unlikely that a fee is considered "solar energy property" for these purposes.

However, users do have the option to adjust for this on the depreciation page, and that page says these fees are included: image

    What are your preferences on including or removing these fees from the new basis variables?
    Do we have a way to notify users that the basis has changed during the patch and they may need to re-check their depreciation allocations? If not, I'm wondering if it makes sense to defer some of these changes to the release.

          > @brtietz , @cpaulgilman To be totally transparent, a checkbox could be used on whether or not to include the fees...However, this would require waiting until the next release. If we wait until the next release, we can notify the user of the bases changes in the Version upgrade script. What do you think?

I like this idea! I'll leave the fees in for the patch in the spirit of making smaller changes, but I still want to remove the reserves at Michele's recommendation which means notifying users (if possible) is still a good idea.

Originally posted by @brtietz in https://github.com/NREL/ssc/issues/1178#issuecomment-2197029201

brtietz commented 1 week ago

https://www.seia.org/research-resources/cost-basis-itc-and-1603-applications has a good discussion of developer fees for the partnership flip model (the checkbox should also probably apply to these).