Priv. Ltr. Rul. 201136018 (May 25, 2011)

(wind farm located in a U.S. possession in which all beneficial owners, either directly or indirectly, are U.S. citizens or domestic corporations, where membership interests sold to investors, is property described in I.R.C. Sec. 168(g)(4)(G) and will not be treated as property that is used predominantly outside the U.S. for ADS purposes).