Historically, only taxpaying entities could take advantage of federal tax credits for renewable energy and other qualifying projects. Tax-exempt entities, such as municipal utilities and rural electrical cooperatives, as well...more
States, municipalities and 501(c)(3) organizations (Issuers) likely will have to incur significant expenses in their fight against COVID-19. Even if Issuers have reserves available for these costs, there are a few different...more
Many clients have been asking questions relating to the current market challenges with VRDOs and CP (high interest rates and lack of demand). The discussion below was drafted to provide some basic information and analysis...more
Many tax-exempt bonds and related hedges, such as interest rate swaps ("Exempt Instruments"), use a LIBOR-based interest rate. LIBOR is going away, and existing Exempt Instruments are going to have to be modified to replace...more
10/29/2019
/ Alternative Reference Rates Committee (ARRC) ,
Exemptions ,
Fair Market Value ,
Financial Instruments ,
Interest Rates ,
IRS ,
ISDA ,
Libor ,
Popular ,
Proposed Regulation ,
Public Finance ,
Regulatory Agenda ,
Rulemaking Process ,
Safe Harbors ,
Secured Overnight Funding Rate (SOFR) ,
Swaps ,
Tax Exemptions ,
Tax Planning ,
Tax Relief
In a private letter ruling (PLR 201918008) publicly released earlier this week, the IRS addressed the statutory safe harbor relating to the allowable term for leases of port and airport facilities financed with tax-exempt...more
On December 28, 2018, the U.S. Department of the Treasury released final regulations (the “Final TEFRA Regulations”) regarding the requirements for public notice, hearing, and approval of qualified private activity bonds...more
In a recently released private letter ruling (Private Letter Ruling 201847001, or the “Ruling”), the IRS approved the use of a “floating equity” allocation method for exempt facility bonds issued to finance renovations to an...more
12/13/2018
/ Airports ,
Bonds ,
Equity ,
IRS ,
Private Letter Rulings ,
Project Finance ,
Public Finance ,
Real Estate Development ,
Retail Market ,
Tax-Exempt Bonds ,
Wine & Alcohol
Last week, the IRS released proposed regulations (“Proposed Regulations”) relating to the so-called TEFRA public notice and approval requirement for private activity bonds. In general, the Proposed Regulations make it easier...more
For a number of years, the IRS Office of Tax-Exempt Bonds ("TEB") has expressed concerns about potential tax abuses that may exist in what it has characterized as "developer-driven deals" involving the use of tax-exempt...more
IRS Revenue Procedure 2017-13 (the "Revenue Procedure") sets forth, and significantly liberalizes, the requirements for determining whether a contract (a "Services Contract") with a service provider or manager (a "Service...more
Qualified Equity - Allocation & Accounting Rules
for Private Business Use -
New Treasury Regulations regarding measurement and allocation of private business use (PBU) benefit universities that finance a...more
11/8/2016
/ Accounting ,
Bonds ,
Educational Institutions ,
Equity ,
Health Care Providers ,
Healthcare Facilities ,
IRS ,
Safe Harbors ,
Service Contracts ,
Tax Exemptions ,
Tax Rates ,
Tax Refunds ,
Universities