Videocast: Section 45Q Carbon Capture and Sequestration (CCS) credit
Facilities owned by nonprofits and government entities are frequently financed with tax-exempt bonds and managed by for-profit management companies. To avoid tainting the tax-exempt status of the interest payable on...more
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
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
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
On April 11, 2018, the Internal Revenue Service published Revenue Procedure 2018-26 (“Rev. Proc. 2018-26”), providing new guidance to issuers on the availability of remedial actions to preserve the status of tax advantaged...more
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
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
Under federal income tax law, the tax-exempt status of a bond is jeopardized if the proceeds of the bond are used for a private business use. Because hospital facilities are often financed with tax-exempt bonds, hospital...more