With its glamorous brand, address, association with and access to an adjoining luxury hotel, a well-designed branded residence project initially appears to offer an “everyone wins” proposal to the participants: the project...more
In the past few years, the IRS has changed its guidance on whether “management contracts” result in private business use for purposes of the restrictions on use of property financed with tax-exempt bonds. This update...more
For the third time in as many years, the Internal Revenue Service (the “IRS”) has issued guidance for determining whether a management contract will result in private business use for property financed with governmental or...more
On Monday, August 22, the Internal Revenue Service (“IRS”) issued Revenue Procedure 16-44 (“Rev. Proc. 16-44”), which revises and expands the safe harbor provisions for long-term management contracts relating to property...more
State and local governments and 501(c)(3) organizations have been given very flexible guidance by the IRS for longer-term private management of tax-exempt bond financed projects to facilitate general operations and major...more