For a variety of reasons, as has been widely reported, LIBOR is to cease to be published by the end of 2021 and this expected elimination of the index upon which financing transactions are based raises serious tax and non-tax...more
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 December 31, 2018, the Department of Treasury and Internal Revenue Service released long-awaited proposed regulations (the “Proposed Regulations”) that address when modifications to the terms of tax-exempt bonds are...more
The Internal Revenue Service (the “IRS”) and The U.S. Department of the Treasury (the “Treasury”) proposed regulations on September 28, 2017 to update and streamline the public approval requirement applicable to tax-exempt...more
On September 28, 2017, the Internal Revenue Service (IRS) withdrew previous proposed regulations and released new proposed regulations (the “Proposed Regulations”) relating to public approval requirements for tax exempt...more
On February 23, 2016, the Internal Revenue Service (IRS) released proposed regulations providing guidance on the definition of a “political subdivision” under the tax-exempt bond rules. A public hearing is scheduled for June...more
On February 22, 2016, the Internal Revenue Service (the “IRS”) released proposed treasury regulations (the “Proposed Regulations” ) to provide guidance as to how the IRS intends to prospectively define a “political...more
On February 22, 2016, the Internal Revenue Service (the “IRS”) published new proposed regulations (the “Proposed Regulations”) in the Federal Register providing guidance as to the definition of a “political subdivision” for...more
In an important development for special districts, including water districts, road districts, and other utility districts, on February 22, 2016, the Internal Revenue Service (“IRS”) released proposed Treasury Regulations (the...more
The U.S. Treasury Department and the Internal Revenue Service (IRS) held a public hearing on the definition of issue price for tax-exempt bonds on October 28, 2015. The hearing is another step in the process of changing what...more
On June 23, 2015, the IRS released new proposed Treasury Regulations (the “2015 Proposed Regulations”) concerning the definition of “issue price” for purposes of arbitrage investment restrictions on tax-exempt bonds. The...more