On November 2, 2017, the Committee on Ways and Means of the U.S. House of Representatives released its highly anticipated proposed tax reform legislation (the “Proposed Legislation”). The Proposed Legislation deals a severe...more
Recently released proposed regulations (the “Proposed Regulations”) relating to the public notice and approval requirements for private activity bonds (the “Public Approval Requirement”) – sometimes referred to as the TEFRA...more
According to an update released by The IRS Office of Tax Exempt Bonds, the sequester reduction percentage applied to the payments made to issuers of direct pay bonds in fiscal year 2018 will be 6.6 percent. This percentage...more
The June 7th effective date for the final Treasury Regulations relating to the establishment of “issue price” of tax-exempt obligations (the “New Regulations”) is drawing near. In fact, for obligations that are scheduled to...more
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
On March 8, 2017, the U.S. Department of the Treasury announced the suspension of sales of United States Treasury Obligations – State and Local Government Series (i.e., SLGS), effective 12:00 noon Eastern Time, March 15,...more
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
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
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
12/12/2016
/ Bond Issuers ,
Bond Markets ,
Bonds ,
Final Rules ,
Financial Adviser ,
IRS ,
New Regulations ,
Offering Price ,
Private Placements ,
Public Offerings ,
Tax-Exempt Bonds ,
U.S. Treasury ,
Underwriting
Coming as welcome news to those involved in the municipal bond market, Revenue Procedure 2016-44 provides helpful guidance for governmental issuers and 501(c)(3) borrowers entering into long-term contracts with private...more
8/24/2016
/ 501(c)(3) ,
Bonds ,
Borrowers ,
Contract Terms ,
Management Contracts ,
Municipal Bonds ,
Municipal Securities Issuers ,
Municipalities ,
Public Finance ,
Public Private Partnerships (P3s) ,
Revenue Procedures ,
Safe Harbors
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 2017 will be 6.9 percent. This percentage will...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
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
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
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
On Friday, October 24, 2014, the Internal Revenue Service (IRS) released Notice 2014-67, providing guidance regarding the circumstances under which participation by a hospital in an Accountable Care Organization (ACO) will...more