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Revenue Procedures Safe Harbors Public Private Partnerships (P3s)

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

Foley & Lardner LLP

An Update on Implementation of New Management Contract Safe Harbors for Property Financed with Tax-Exempt Bonds

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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

Bracewell LLP

IRS Provides Issuers Of Tax-Advantaged Debt with New "DIY" Tools to Fix Nonqualified Use

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On April 11, 2018, the IRS released Revenue Procedure 2018-26 (“Rev. Proc. 2018-26”), which provides an expansion of the remedial actions available to issuers of tax-advantaged bonds. Specifically Rev. Proc. 2018-26 provides:...more

Mintz - Public Finance Viewpoints

IRS Expands Remedial Action for Nonqualified Use of Tax-Advantaged Bonds

The IRS on April 11, 2018 released Revenue Procedure 2018-26 (Rev. Proc. 2018-26), which expands remedial action options in connection with certain post-issuance leases to private parties of facilities financed with...more

Bracewell LLP

Management Contracts & Private Business Use–IRS Releases Favorable Guidance

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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

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