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Treasury and IRS Release Final Tax Regulations for LIBOR Replacement Amendments

The lengthy saga of the transition to a post-LIBOR world reached a degree of finality on the tax side with the issuance by the Department of Treasury and Internal Revenue Service (IRS) of long-awaited final regulations (the...more

Final Section 529A ABLE Plan Regulations Are Well-Intended But Will Require Further Clarification

On October 2, 2020, the Internal Revenue Service released final regulations providing guidance for Section 529A “qualified ABLE programs” established by states under the Stephen Beck Jr. Achieving a Better Life Experience Act...more

SOFR So Good! IRS Makes It Easier to Say ‘Goodbye’ to LIBOR

Lenders, creditors and swap parties may finally begin to replace LIBOR with confidence. While LIBOR’s demise was announced in 2017, efforts to amend the vast pool of LIBOR-based bonds and swaps to reference a replacement...more

IRS Expands Remedial Action for Nonqualified Use of Tax-Advantaged Bonds

The IRS on April 11, 2018 released Revenue Procedure 2018-26 (Rev. Proc. 2018-26), which expands remedial action options in connection with certain post-issuance leases to private parties of facilities financed with...more

IRS Releases New Public Approval Proposed Regulations

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

ABLE Programs and Beneficiaries Boosted by Helpful Guidance from IRS and Social Security Administration

The Stephen Beck, Jr., Achieving a Better Life Experience Act of 2014 (ABLE Act), one of the few recent examples of bipartisan cooperation on a new category of tax and budget expenditure, is both well-intentioned in its...more

The IRS’s Proposed ABLE Regulations: Obstacles for Launching State Programs, and Potential Solutions

The IRS’s recently-published proposed regulations for Section 529A qualified ABLE programs have taken some wind out of the sails of state program administrators and potential program managers who had hoped for regulations...more

6/30/2015  /  Disability , IRS , Section 529A

IRS’s Proposed Section 529A Regulations for ABLE Programs: A Mixed Bag

The IRS today published, right on deadline, its proposed regulations relating to Section 529A state-sponsored “qualified ABLE programs,” under which tax-advantaged investment accounts may be established to fund future...more

IRS Green Lights Section 529A ABLE Disability Programs

Pi Day comes but once a century, on 3/14/15. The Internal Revenue Service receives praise approximately as frequently. But the IRS deserves applause for its Notice 2015-18, released March 10, 2015, giving the green light to...more

Off-Key BABs: IRS Hits Wrong Note in Reissuance Analysis

The IRS recently published a December 9, 2014 Chief Counsel Advice Memorandum to the effect that the defeasance of taxable Build America Bonds (BABs) causes a tax reissuance of the bonds, with the consequence that the...more

IRS Ruling Treats Certain 529 Account Incentive Payments as Reportable Income

The IRS recently issued a private letter ruling, PLR 201310043 (released on March 8, 2013), of interest to Section 529 plans and their program managers. The ruling relates to the tax treatment of incentive contributions to...more

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