News & Analysis as of

Tax-Exempt Bonds Internal Revenue Service

IRS Guidelines Provide Greater Flexibility to Nonprofit Borrowers

by Polsinelli on

New guidelines from the Internal Revenue Service substantially overhaul safe harbors that have existed for 20 years. Specifically, the IRS recently released Revenue Procedure 2017-13 (“Rev. Proc. 2017-13”), which establishes...more

IRS Expands Management Contract Guidelines for Projects Financed with Tax-Exempt Bonds

by Holland & Knight LLP on

The Internal Revenue Service (IRS) earlier this year released Rev. Proc. 2017-13 (the Guidelines), which contained new safe harbors for qualified management contracts relating to facilities financed with tax-exempt bonds. The...more

Availability of Tribal Economic Development Bond Allocations

by Holland & Knight LLP on

Based on a recent Internal Revenue Service (IRS) announcement, the Published Value Cap Limit for Tribal Economic Development Bonds (TEDBs) is steadily shrinking...more

IRS to Begin New Procedure for Initiating Tax-Exempt Bond Audits

by Bracewell LLP on

In late 2016, the IRS Tax-Exempt and Government Entities Division (“TE/GE”) released a memorandum to its examiners outlining a new procedure for initiating audits of tax-exempt bonds. The Commissioner of TE/GE recently noted...more

New Regulations on Issue Price of Tax-Exempt Bonds

by Foley & Lardner LLP on

On December 9, 2016, the Department of the Treasury and Internal Revenue Service (IRS) published final regulations on the definition of “issue price,” for purposes of the arbitrage rules that apply to tax-exempt bonds....more

Introduction to Tax For Public Finance – Tax Presentation

Introduction to Tax for Public Finance - • What is the tax-exemption for state and local bonds? • Types of tax-exempt bonds • Overview of federal income tax requirements... Please see full Publication...more

The New Issue Price Regulations: The Good, the Bad and the Ugly

by Bracewell LLP on

Late last year, the Treasury Department released final Treasury Regulations (the “New Regulations”) relating to the “issue price” of tax-exempt bonds, effective for bonds sold after June 7, 2017. Because the changes imposed...more

Public Finance Advisory: IRS Releases Clarifying Management Contracts Rules

by Sherman & Howard L.L.C. on

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

IRS Issues Clarification for Tax-Exempt Management Contracts - Impact on Healthcare Providers

by Shipman & Goodwin LLP on

In IRS Revenue Procedure 2017-13 (Rev. Proc. 2017-13), the IRS clarifies safe harbor conditions under which a management contract will not result in private business use of a property financed by tax-exempt bonds. By way...more

IRS Issues New Guidelines for Qualified Management Contracts for Facilities Financed with Tax Exempt Bonds

by Dickinson Wright on

Health care providers with facilities financed with tax exempt bonds need to be aware of recent changes to the IRS rules for qualified management contracts. On August 22, 2016, the IRS issued Rev. Proc. 2016-44 which...more

Management Contracts Safe Harbors Revisited – IRS Releases Updated Guidance (Again)

by Bracewell LLP on

Demonstrating the “user-friendly” side of the IRS, on January 17, 2017, the IRS released Revenue Procedure 2017-13 (“Rev. Proc. 2017-13”) (available here) to address many (but not all) of the comments received on the rather...more

IRS Publishes Final Issue Price Rules for Tax-Exempt Municipal Bond Offerings

by Clark Hill PLC on

The Internal Revenue Service ("IRS") has approved final issue price regulations under Section 148 of the Internal Revenue Code, effective for bond offerings sold on or after June 7, 2017. The new definition of issue price...more

IRS Releases New Issue Price Rules

by Cozen O'Connor on

On December 9, 2016, the Internal Revenue Service (the IRS) released new regulations under Section 148 of the Internal Revenue Code of 1986, as amended, (referred to herein as the code) regarding the determination of the...more

Final Treasury Regulations Defining Issue Price

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

Final Issue Price Regulations Significantly Change Current Rules

by Bracewell LLP on

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

IRS Eases Safe Harbor Conditions Under Which a Contract with a Hospital Will Not Result in Private Business Use of Tax-Exempt...

by Roetzel & Andress on

Under federal income tax law, the tax-exempt status of a bond is jeopardized if the proceeds of the bond are used for a private business use. Because hospital facilities are often financed with tax-exempt bonds, hospital...more

Rev. Proc. 2016-44: Greater Flexibility in IRS Safe Harbor for Management Contracts

by Jackson Walker on

Recently, the IRS released a safe harbor from private use of tax-exempt bond-financed facilities for management contracts that profoundly changes the safe harbors that have been in place under Rev. Proc. 97-13 for almost 20...more

IRS Continues Trend of Flexibility for Qualified Management Agreements (QMA’s) for Hotels Financed With Tax Exempt Bonds

by Kelley Drye & Warren LLP on

The US Internal Revenue Service (IRS) recently continued a trend of pronouncements further extending flexibility in structuring a Qualified Management Agreement (QMA) for a hotel financed with tax exempt bonds without...more

IRS Releases Guidance on Management Contracts

by Cozen O'Connor on

Revenue Procedure 2016-44 replaces the long-standing safe harbors in Revenue Procedure 97-13 for analyzing private business use under management contracts with a more flexible safe harbor, but requires specific provisions in...more

IRS Issues New Management Contract Safe Harbors

by Sherman & Howard L.L.C. on

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

New Management Contract Safe Harbors

by McCarter & English, LLP on

The Internal Revenue Service (the “IRS”) released Revenue Procedure 2016-44 (“Rev. Proc. 2016-44”) on August 22, 2016 to provide new safe harbors for management contracts to avoid characterization of such contracts as private...more

IRS releases updated safe harbors for management contracts in tax-exempt bond-financed projects

by Thompson Coburn LLP on

On August 22, 2016, the Internal Revenue Service released Revenue Procedure 2016-44. The purpose of this revenue procedure is to provide revised and broader “safe harbors” under which certain private management contracts will...more

IRS Loosens Restrictions on Safe Harbors for Management Contracts for Bond-Financed Property

The Internal Revenue Service, in Revenue Procedure 2016-44, has loosened the restrictions on safe harbors for management contracts entered into by governmental issuers of tax-exempt bonds in connection with facilities...more

New IRS Management Guidance is Flexible, Furthers P3s

by 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

IRS Publishes New Management Contract Safe Harbors for Property Financed with Tax-Exempt Bonds

by Foley & Lardner LLP on

On August 22, 2016, the Internal Revenue Service (IRS) released Rev. Proc. 2016-44, which provides new guidance on the treatment of “management contracts” for purposes of the restrictions on use of property financed with...more

61 Results
|
View per page
Page: of 3
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.