According to the IRS website, the sequester reduction rate applied to payments made to issuers of direct pay tax credit bonds in fiscal year 2021 will be 5.7 percent. This percentage will apply to all subsidy payments...more
Responding to volatility in the market and liquidity constraints caused by the COVID-19 pandemic, in Notice 2020-25 (the “Notice”), the IRS provides temporary relief for governmental issuers seeking to purchase their own...more
As a result of the prohibitions on public gatherings resulting from the COVID-19 pandemic, issuers of tax-exempt private activity bonds have been facing difficulty complying with the federal tax laws requiring that a public...more
On April 23, 2020, the IRS and the Treasury Department released Proposed Regulations that provide guidance for how tax-exempt organizations (“EOs”) conducting multiple unrelated trades or businesses can calculate their...more
As a result of the COVID-19 pandemic, in Notice 2020-23 the IRS extended the due date for issuers of tax-exempt obligations to file Forms 8038 or 8038-G for transactions that closed during the first quarter of 2020. ...more
Good news for tax-exempt organizations! The “Further Consolidated Appropriations Act, 2020” (H.R. 1865 — 116th Congress (2019-2020)) (the “Act”) signed into law on December 20, 2019, retroactively repealed Section 512(a)(7)...more
The Bipartisan Budget Act of 2019 (the “Act”), which suspends the federal debt limit through July 31, 2021, was signed into law on August 2, 2019. As a result, the U.S. Department of the Treasury has announced that it will...more
According to the IRS website, the sequester reduction rate applied to payments made to issuers of direct pay tax credit bonds in fiscal year 2020 will be 5.9 percent. This percentage will apply to all subsidy payments...more
The IRS recently issued a Private Letter Ruling (the “PLR”) revoking a hospital organization’s section 501(c)(3) status for failing to comply with the section 501(r) requirements. In what may be a sign of things to come, the...more
As is well known, on December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Final Bill”) into law. During the course of this massive legislative effort, various provisions affecting tax-exempt organizations...more
6/1/2018
/ 501(c)(3) ,
Charitable Donations ,
Excise Tax ,
Executive Compensation ,
Income Taxes ,
IRS ,
New Rules ,
Nonprofits ,
Remuneration ,
Tax Cuts and Jobs Act ,
Tax Exempt Entities ,
Tax Incentives ,
Tax Reform
On December 15, 2017, the conference committee on tax reform (the “Conference Committee”) released its Conference Report (the “Conference Report”) describing the agreements forged to reconcile differences between the...more
On December 6, 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, Friday,...more
An article released by The Bond Buyer on November 14, 2017, reports that, if Congress were to pass the proposed legislation released by the Committee on Ways and Means of the U.S. House of Representatives on November 2, 2017...more
On November 9, 2017, the U.S. Senate Finance Committee released the Description of the Chairman’s Mark of the “Tax Cuts and Jobs Act” (the “Senate Finance Committee Mark”), which sets forth a summary of the proposed tax...more
11/13/2017
/ 501(c)(3) ,
Debt Restructuring ,
Infrastructure Financing ,
Municipal Bonds ,
Proposed Legislation ,
Refunds ,
Senate Finance Committee ,
State and Local Government ,
Tax Reform ,
Tax-Exempt Bonds ,
Ways and Means Committee
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
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
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
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
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 2016 will be 6.8 percent. This percentage will...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
Several proposals affecting tax-exempt bonds were included in the Obama Administration's Budget for FY 2016. As usual, the overall budget proposal has immediately been declared DOA by political pundits. Nonetheless, taking...more