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Internal Revenue Service Service Contracts

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Miller Canfield

Amount Realized and Cost Basis in a Property Transaction With Hard-to-Value Property

Miller Canfield on

In Private Letter Ruling 202352011 (December 30, 2023), the taxpayer asked the IRS to determine the amount that it will realize in a property transaction. The taxpayer will receive the property in an arm’s length exchange...more

Foley & Lardner LLP

An Update on Implementation of New Management Contract Safe Harbors for Property Financed with Tax-Exempt Bonds

Foley & Lardner LLP on

In the past few years, the IRS has changed its guidance on whether “management contracts” result in private business use for purposes of the restrictions on use of property financed with tax-exempt bonds. This update...more

Smith Anderson

Draft North Carolina Tax Legislation Released

Smith Anderson on

On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more

McDermott Will & Emery

Bond-Financed Hospitals Must Apply New IRS Rules to Service Contracts

After nearly two decades of restructuring service agreements to comply with Internal Revenue Service safe harbors, hospitals and other 501(c)(3) organizations are now subject to a new set of guidance and a single safe harbor...more

Sherman & Howard L.L.C.

Public Finance Advisory: IRS Releases Clarifying Management Contracts Rules

For the third time in as many years, the Internal Revenue Service (the “IRS”) has issued guidance for determining whether a management contract will result in private business use for property financed with governmental or...more

Mayer Brown

IRS Provides Safe Harbor for Solar Contracts with Federal Agencies

Mayer Brown on

On January 19, 2017, the US Internal Revenue Service (IRS) released Revenue Procedure 2017-19 (the “Rev. Proc.”) providing a safe harbor for certain alternative energy sales contracts with federal agencies to be treated as...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

Sherman & Howard L.L.C.

IRS Issues New Management Contract Safe Harbors

On Monday, August 22, the Internal Revenue Service (“IRS”) issued Revenue Procedure 16-44 (“Rev. Proc. 16-44”), which revises and expands the safe harbor provisions for long-term management contracts relating to property...more

Ballard Spahr LLP

New IRS Management Guidance is Flexible, Furthers P3s

Ballard Spahr LLP on

State and local governments and 501(c)(3) organizations have been given very flexible guidance by the IRS for longer-term private management of tax-exempt bond financed projects to facilitate general operations and major...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

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