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Internal Revenue Code (IRC) Bonds

Allen Matkins

The Possible Securities Act Implications Of Harvard's "Nyet" To Government Civil Rights Reform Demands

Allen Matkins on

Last week, the United States General Services Administration, Department of Education, and Department of Health and Human Services sent a letter to Alan M. Garber, the President of Harvard University, and Penny Pritzker, Lead...more

Holland & Knight LLP

IRS Releases Final Regulations on Reissuance and Retirement of Tax-Exempt Tender Option Bonds

Holland & Knight LLP on

The IRS released on Dec. 30, 2024, final regulations on Sections 1.150-3 and 1.1001-3(a)(2) (the Regulations) regarding the reissuance and retirement (debt extinguishment) of tax-exempt tender option bonds....more

Orrick, Herrington & Sutcliffe LLP

Attention BAB Issuers: Extraordinary Optional Redemption is Available

For more than 10 years, as the subsidy for direct payment Build America Bonds (BABs) has been less than originally promised due to sequestration, issuers have wondered if sequestration constituted an “extraordinary event”...more

Cadwalader, Wickersham & Taft LLP

Exchange Trust Certificates in REMIC Transactions Qualify as Stripped Bonds or Coupons

On November 24, 2023, the IRS released PLR 202347001, ruling that certificates issued from an “exchange trust” qualify as stripped bonds or stripped coupons within the meaning of Code Section 1286. The taxpayer in the...more

ArentFox Schiff

Self-Directed IRAs and the Prohibited Transaction Rules – Part 1

ArentFox Schiff on

Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...more

Eversheds Sutherland (US) LLP

Florida District Court of Appeals hears oral arguments in addback dispute

​​​​​​​On October 11, 2022, the Florida District Court of Appeals, First District held oral arguments on State Farm Mutual Automobile Insurance Company v. Florida Department of Revenue, a case relating to the “add back” to...more

McDermott Will & Emery

Weekly IRS Roundup September 19 – September 23, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 19, 2022 – September 23, 2022....more

McDermott Will & Emery

Key Digital Asset Tax Proposals in the Biden Administration's Green Book

On March 28, 2022, the US Department of the Treasury released the Fiscal Year (FY) 2023 Revenue Proposals and Green Book, which describes the tax proposals in the Biden administration’s FY 2023 budget (2023 Budget Proposal)....more

Mitchell, Williams, Selig, Gates & Woodyard,...

New Federal Legislation Eases Access to Financing for Broadband Projects with Qualified Private Activity Bonds

Congress has passed the Infrastructure Investment and Jobs Act of 2021, which President Biden signed on November 15, 2021. The Act includes approximately $65 billion in funding opportunities for the deployment of broadband...more

Butler Snow LLP

Tax-Exempt Advance Refunding Bonds: History and Legislative Updates

Butler Snow LLP on

Prior to January 1, 2018, Section 149(d) of the Internal Revenue Code (26 U.S.C. § 149) and the accompanying Treasury Regulations allowed the issuance of tax-exempt advance refunding bonds. According to that section, a bond...more

Bracewell LLP

FY 2021 Sequestration Reduction Rate for Direct Pay Tax Credit Bonds Set at 5.7%

Bracewell LLP on

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

Partridge Snow & Hahn LLP

IRS Private Letter Ruling Provides New Guidance On Calculating Economic Life of Certain Bond-Financed Assets

The IRS has released a Private Letter Ruling that approves a simplified method of calculating the remaining economic life of property financed with exempt facility bonds. Section 142 of the Internal Revenue Code (the “Code”)...more

McGuireWoods LLP

IRS Clarifies Acceptable Tenant Preferences for Affordable Multifamily Housing Bonds

McGuireWoods LLP on

On April 3, the IRS issued Revenue Procedure 2019-17 (Rev. Proc.), offering additional guidance on the public use requirement applicable to multifamily housing bonds under Section 142(d) of the Internal Revenue Code. This new...more

McGuireWoods LLP

Final Private Activity Bond Public Approval Regulations: Three Key Takeaways

McGuireWoods LLP on

An issue of private activity bonds will not qualify for tax-exempt status unless the bond issue has satisfied the "public approval" requirement of Section 147(f) of the Internal Revenue Code of 1986, as amended. The bond...more

Bracewell LLP

FY 2019 Sequestration Reduction Rate for Direct Pay Tax Credit Bonds Set at 6.2 Percent

Bracewell LLP on

According to the IRS website, the sequester reduction rate applied to payments made to issuers of direct pay tax credit bonds in fiscal year 2019 will be 6.2 percent. This percentage will apply to all subsidy payments...more

Allen Matkins

Industrial Development Bonds And The Mystery Of Federal Preemption

Allen Matkins on

This should be a straightforward question - Are qualification and registration requirements under state securities laws preempted with respect to industrial development bonds? When Congress enacted the National Securities...more

Foley & Lardner LLP

Tax Reform and Tax-Exempt Bonds: Risks Presented by the Tax Cuts and Jobs Act

Foley & Lardner LLP on

On November 2, 2017, the “Tax Cuts and Jobs Act” was introduced in the House of Representatives. This act has immediate and far-reaching implications for tax-exempt finance. Among other things, the Tax Cuts and Jobs Act...more

Ballard Spahr LLP

Federal Tax Reform: House Bill Rewrites Municipal Bond Rules

Ballard Spahr LLP on

The proposed Tax Cuts and Jobs Act released last week would eliminate the federal tax exemption for interest earned on all private activity bonds—including 501(c)(3) bonds and exempt facility bonds—and advance refunding bonds...more

Mintz - Public Finance Viewpoints

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

Orrick, Herrington & Sutcliffe LLP

Audits of Multifamily Housing Bonds Triggered by Failure to File Form 8703

IRC Section 142(d) requires operators of qualified residential rental properties to file Form 8703, Annual Certification of a Residential Rental Project annually. A number of recent audits of multifamily housing bonds appear...more

Cozen O'Connor

IRS Releases New Issue Price Rules

Cozen O'Connor on

On December 9, 2016, the Internal Revenue Service (the IRS) released new regulations under Section 148 of the Internal Revenue Code of 1986, as amended, (referred to herein as the code) regarding the determination of the...more

Holland & Knight LLP

Legislative Opportunities for Tribal Governments Under the Trump Administration

Holland & Knight LLP on

With the advent of a Republican-controlled White House and Congress, many who work in Washington, D.C., on behalf of Indian tribes may be tempted to adopt a defensive posture. But while it always is important to defend tribal...more

Miller Canfield

State and local governments continue to see a reduction in credits available for Direct Pay Bonds

Miller Canfield on

As a result of federal sequestration, state and local governments who have issued certain direct pay bonds have seen a reduction in tax subsidy payments since March 1, 2013. Sequestration is a result of Congress’ failure to...more

Eversheds Sutherland (US) LLP

IRS Announces $281 Million Available Under New CREBs Program

On February 3, the Internal Revenue Service (IRS) released Notice 2015-12 (the Notice) which solicited applications for a third round of allocations of volume cap for new clean renewable energy bonds (New CREBs) under Section...more

Eversheds Sutherland (US) LLP

Required Summer Reading: Guidance Issued on the Tax Treatment of Guaranteed Minimum Benefit Hedges and Identified Mixed Straddles

The Treasury and the IRS offered two pieces of highly anticipated guidance on July 18 that are particularly relevant to the life insurance industry. ...more

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