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Internal Revenue Code (IRC) Bonds Internal Revenue Service

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

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

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

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

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

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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