News & Analysis as of

New IRS Standards for Qualified Management Contracts

A few weeks ago the Internal Revenue Service released a new notice with allows 501(c)(3) organizations with tax-exempt bonds greater flexibility in drafting their management agreements. In the past, entities with outstanding...more

Final Treasury Regulations Set Deadline for Arbitrage Rebate Overpayment Claims

Effective November 13, 2014, the filing deadline for a claim for an arbitrage rebate overpayment on tax-exempt and other tax-advantaged bonds is two years after the final arbitrage computation date for the issue from which...more

Internal Revenue Service Releases Interim Guidance Regarding Accountable Care Organizations' Use Of Tax-Exempt Bond-Financed...

On October 24, 2014, the Internal Revenue Service (IRS) released Notice 2014-67, which provides guidance for determining whether a state or local governmental entity or an organization described by Section 501(c)(3) of the...more

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

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

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

FY 2015 Sequestration Reduction Percentage for Direct Pay Tax Credit Bonds Bumps Up to 7.3 Percent

According to an update released by The IRS Office of Tax Exempt Bonds (TEB), the sequester reduction percentage applied to the payments made to issuers of direct pay bonds in FY 2015 will be 7.3 percent. This new percentage...more

Draw down bonds and date of issuance: questions remain with IRS guidance

For many years multifamily housing apartment projects could be financed with tax-exempt drawn-down bonds and loans with all of the bonds issued pursuant to a draw-down loan being treated as part of a single issue. The date of...more

Post-Issuance Tax Compliance and Continuing Disclosure Responsibilities for Issuers and Borrowers of Tax-Exempt Bonds

Chapter One: Introduction: Why Post-Issuance Compliance? Over the past few years, the tax-exempt bond market has been under heightened scrutiny by various regulators, including the Internal Revenue Service...more

Decision on Florida CDD Has Broad Implications for Tax-Exempt Bonds

The IRS issued a Technical Advice Memorandum (TAM) on May 9, 2013, that the Village Center Community Development District (the "District") is not a division of state or local government, and therefore is not a political...more

Corporate & Tax E-Note - March 28, 2013

In This Issue: - SEC Yet to Release Jumpstart Our Business Startups Act Guidelines - IRS Crackdown on Contract Workers Has Small Businesses Concerned - Accelerated Filers Found to be Filing More Restatements -...more

Five Things To Know When Contemplating the Issuance of Municipal Debt

Municipal financings are often perceived as a very complex, and even overwhelming, undertaking. The various rules and regulations which govern the process oftentimes seem complicated and difficult to understand. Keep in mind...more

New 3.8% Medicare Tax on Investment and Unearned Income Beginning in 2013

Starting January 1, 2013, a new 3.8% Medicare tax will apply to the investment and “unearned income” of individuals, trusts and estates. The tax is intended to apply to income exempt from the regular FICA or self-employment...more

IRS Releases Guidance on Refinancing Projects Financed with Go Zone Bonds

The IRS has released Notice 2012-3, which provides that projects originally financed with tax-exempt Gulf Opportunity Zone Bonds (“GO Zone Bonds”) may be refinanced on a tax-exempt basis after December 31, 2011, the date on...more

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