Many conduit tax exempt revenue bonds bear interest at a floating rate, most typically a percent of USD 1-month LIBOR (here, LIBOR). Many of these transactions have been synthetically “fixed” by the conduit borrower entering...more
On November 2, 2017, the “Tax Cuts and Jobs Act” was introduced in the House of Representatives. This act has immediate and far-reaching implications for tax-exempt finance. Among other things, the Tax Cuts and Jobs Act...more
For a variety of reasons related to arbitrage, it often is important to identify the "issue price" of tax-exempt bonds with precision and certainty. Existing Treasury Regulations generally allow the "issue price" of publicly...more
On December 9, 2016, the IRS released final Treasury Regulations (the “Final Regulations”) relating to the “issue price” of tax-exempt bonds for purposes of arbitrage investment restrictions. Although, on balance, an...more
On October 26, 2015, the IRS released final regulations (the “Final Regulations”) regarding allocation and accounting rules for purposes of the private activity bond restrictions applicable to tax-exempt bonds issued by state...more
The Treasury Department published in the June 24, 2015 Federal Register new proposed regulations for determining the “issue price” of bonds. The same announcement also withdrew the proposed regulations published in 2013 (the...more