News & Analysis as of

Internal Revenue Service Bonds

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
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

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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

Rivkin Radler LLP

Strategies for Giving to a Favorite Charity

Rivkin Radler LLP on

You may already know about many of the amazing things the North Shore Land Alliance has done to protect our beloved Long Island. The mission of the Land Alliance is: “To conserve and safeguard Long island’s natural and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden’s 2023 Insights – Five Critical Areas for the Year Ahead

The pandemic’s impact may be subsiding, but businesses are encountering new challenges across the globe, including the potential for an economic retrenchment, rising interest rates, shifting regulatory and litigation...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

K&L Gates LLP

Permanent Dial-In Option Makes TEFRA Hearings Easier Than Ever – Forever

K&L Gates LLP on

The Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) requires a public hearing as a form of public approval for certain types of tax-exempt private activity bonds. Thanks to COVID-19, holding a hearing is easier than...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

Ballard Spahr LLP

Tax-Exempt Bonds: Telephonic Public Hearings Now Permanent

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For public hearings held on or after March 18, 2022, new Revenue Procedure 2022-20, released by the Internal Revenue Service, allows issuers and approving governmental units to conduct telephonic public hearings for...more

Bricker Graydon LLP

IRS announces changes to Form 8038-CP coming in January 2022

Bricker Graydon LLP on

On November 16, 2021, the Internal Revenue Service (IRS) publicly previewed a draft of a revised Form 8038-CP (Return for Credit Payments to Issuers of Qualified Bonds), along with updated filing instructions and a new...more

Holland & Knight LLP

IRS Promotes Use of Fallback Language to Assist with Libor, IBOR Transition

Holland & Knight LLP on

The Internal Revenue Service (IRS) released Revenue Procedure 2020-44 to assist the market's transition from the London Interbank Offered Rate (Libor) and other interbank offered rates (IBORs) to alternative reference rates...more

Butler Snow LLP

Alternatives to Tax-Exempt Advance Refunding Bonds

Butler Snow LLP on

As described in “Tax-Exempt Advance Refunding Bonds: History and Legislative Updates” by Caitlyn Smith Burchfield, the Tax Cuts and Jobs Act of 2017 bans the issuance of tax-exempt advance refunding bonds after December 31,...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

McDermott Will & Emery

Weekly IRS Roundup March 22 – March 26, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Serve (IRS) guidance and relevant tax matters for the week of March 22, 2021 ­­– March 26, 2021... March 22, 2021: The IRS issued Notice 2021-22, providing...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

Ballard Spahr LLP

Bond Relief Amid COVID-19 Restrictions: Telephonic Public Hearings and Enhanced Issuer Ability to Purchase Bonds

Ballard Spahr LLP on

The IRS provided much-awaited relief for issuers seeking to do a public hearing for their bonds amidst the current pandemic situation. The IRS guidance, Revenue Procedure 2020-21, permits a public hearing to be held by...more

Orrick, Herrington & Sutcliffe LLP

Federal Tax Law Considerations for Financings COVID 19 Costs on a Tax Exempt Basis: What Issuers Need to Know

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

Orrick, Herrington & Sutcliffe LLP

Tax Issues for VRDO Liquidity Problems

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

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

McDermott Will & Emery

Weekly IRS Roundup January 13 – 17, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13 – 17, 2020. January 13, 2020: The IRS published an information letter relating to the...more

Bracewell LLP

An Alternative Structure for Certain P3 Projects – The 63-20 Financing

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With all of the talk about the need for infrastructure legislation, public-private partnerships (or “P3s”) are receiving increased national attention. What exactly constitutes a P3 is an ever-evolving question, and the...more

Bracewell LLP

FY 2020 Sequestration Reduction Rate Set at 5.9%

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 2020 will be 5.9 percent. This percentage will apply to all subsidy payments...more

Partridge Snow & Hahn LLP

IRS Provides Guidance On Current Refunding Of Bonds Issued Under Targeted Bond Programs

IRS Notice 2019-39 sets forth certain requirements for preserving the tax-exempt or tax-advantaged status of current refunding bonds that are issued to refinance bonds that were originally issued under targeted bond programs....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

Cozen O'Connor

IRS Updates, Modernizes and Simplifies TEFRA Public Notice and Approval Regulations

Cozen O'Connor on

Final TEFRA regulations issued by the IRS were published in the Federal Register on December 31, 2018. They apply to qualified private activity bonds (e.g., qualified 501(c)(3) bonds and exempt facility bonds) issued pursuant...more

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