News & Analysis as of

Bonds Safe Harbors

Holland & Knight LLP

IRS Promotes Use of Fallback Language to Assist with Libor, IBOR Transition

Holland & Knight LLP on

The Internal Revenue Service (IRS) released Revenue Procedure 2020-44 to assist the market's transition from the London Interbank Offered Rate (Libor) and other interbank offered rates (IBORs) to alternative reference rates...more

Bracewell LLP

An Alternative Structure for Certain P3 Projects – The 63-20 Financing

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With all of the talk about the need for infrastructure legislation, public-private partnerships (or “P3s”) are receiving increased national attention. What exactly constitutes a P3 is an ever-evolving question, and the...more

Bracewell LLP

IRS Provides Issuers Of Tax-Advantaged Debt with New "DIY" Tools to Fix Nonqualified Use

Bracewell LLP on

On April 11, 2018, the IRS released Revenue Procedure 2018-26 (“Rev. Proc. 2018-26”), which provides an expansion of the remedial actions available to issuers of tax-advantaged bonds. Specifically Rev. Proc. 2018-26 provides:...more

Orrick, Herrington & Sutcliffe LLP

Outline for Discussion of New Issue Price Rules

New tax rules relating to establishing the issue price of publicly offered tax-exempt bonds become effective soon. This outline describes the new issue price rules, provides a high-level strategic analysis to help guide a...more

Orrick, Herrington & Sutcliffe LLP

IRS Revenue Procedure 2017–13 Safe Harbor Requirements for Services Contracts

IRS Revenue Procedure 2017-13 (the "Revenue Procedure") sets forth, and significantly liberalizes, the requirements for determining whether a contract (a "Services Contract") with a service provider or manager (a "Service...more

Orrick, Herrington & Sutcliffe LLP

Higher Education, Exempt Organization & Governmental Financings - Tax Presentation

Qualified Equity - Allocation & Accounting Rules for Private Business Use - New Treasury Regulations regarding measurement and allocation of private business use (PBU) benefit universities that finance a...more

Nossaman LLP

New Management Contract Rules Hot Topic At NABL Conference

Nossaman LLP on

Over a thousand US public finance attorneys converged on the City of Chicago last week for the annual National Association of Bond Lawyers Bond Attorneys Workshop. The conference, the oldest and largest of its kind, featured...more

Bracewell LLP

Management Contracts & Private Business Use–IRS Releases Favorable Guidance

Bracewell LLP on

Coming as welcome news to those involved in the municipal bond market, Revenue Procedure 2016-44 provides helpful guidance for governmental issuers and 501(c)(3) borrowers entering into long-term contracts with private...more

Adler Pollock & Sheehan P.C.

Glossary of Important Securities Regulation Terms and Definitions

This Glossary is designed to provide law students taking Securities Regulation with a tool that will assist them in learning the basic language of securities law and achieve a working knowledge of the fundamental principles...more

Parker Poe Adams & Bernstein LLP

Internal Revenue Service Releases Notice Liberalizing the Private Business Use

On October 24, 2014, the Internal Revenue Service (“IRS”) released Notice 2014-67 (the “Notice”), providing guidance with respect to Accountable Care Organizations and their use of tax-exempt bond financed projects. The...more

Foley & Lardner LLP

IRS Releases Favorable Private Business Use Rules for Facilities Financed With Tax-Exempt Bonds

Foley & Lardner LLP on

On October 24, 2014, the IRS released Notice 2014-67, which establishes more favorable safe harbors for types of service contracts and other arrangements using property financed with tax-exempt bonds. The Notice also provides...more

McCarter & English, LLP

Notice 2014-67—Safe Harbors for ACOs and a New Management Contract Safe Harbor for Everyone

McCarter & English, LLP on

On Friday, Oct. 24, 2014, the Internal Revenue Service released interim guidance, Notice 2014-67, on whether a state or local government entity or an organization described in §501(c)(3) of the Internal Revenue Code of 1986,...more

Smith Anderson

The National Defense Authorization Act of 2013 will Change Small Business Contracting and Teaming

Smith Anderson on

Federal government contractors that contract or team with small businesses must become familiar with recent changes resulting from the National Defense Authorization Act of 2013, signed into law in early January (the “NDAA”)....more

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