News & Analysis as of

Tax-Exempt Bonds Bonds Internal Revenue Service

Ballard Spahr LLP

Tax-Exempt Bonds: Telephonic Public Hearings Now Permanent

Ballard Spahr LLP on

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

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

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

Bracewell LLP

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

Bracewell LLP on

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

Orrick, Herrington & Sutcliffe LLP

Bottled Booze in the Boarding Area IRS Ruling Permits Use of Floating Equity in Airport Exempt Facility Private Activity Bond...

In a recently released private letter ruling (Private Letter Ruling 201847001, or the “Ruling”), the IRS approved the use of a “floating equity” allocation method for exempt facility bonds issued to finance renovations to an...more

Winstead PC

Airports Now Have Greater Flexibility in Tax-Exempt Financing and Leasing Retail Portions of Their Terminals

Winstead PC on

Under a new Internal Revenue Service private letter ruling, issuers of tax-exempt bonds and conduit borrowers now have a greater degree of flexibility to use “qualified equity” for “prohibited uses” without endangering the...more

Miles & Stockbridge P.C.

IRS Expands Remedial Action Options for Tax-Exempt Bonds

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

Bracewell LLP

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

Bracewell LLP on

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

Locke Lord LLP

Summary of the Impact of the Proposed Tax Cuts and Jobs Act on State and Local Bonds

Locke Lord LLP on

On November 2, 2017, the Tax Cuts and Jobs Act (the “Bill”) was introduced in the United States House of Representatives and is currently before the House Ways and Means Committee. The Bill proposes both direct and indirect...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

Best Best & Krieger LLP

Tax Bill Impacts - Immediate, Critical Impacts on State and Local Governments

The U.S. House of Representatives Republican tax bill released yesterday would impact state and local government issuers of tax-exempt bonds in a few significant ways. ...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

IRS Focuses on Tax Exempt Financings Involving Developers

For a number of years, the IRS Office of Tax-Exempt Bonds ("TEB") has expressed concerns about potential tax abuses that may exist in what it has characterized as "developer-driven deals" involving the use of tax-exempt...more

Bracewell LLP

FY 2018 Sequestration Reduction Percentage for Direct Pay Tax Credit Bonds Set at 6.6 Percent

Bracewell LLP on

According to an update released by The IRS Office of Tax Exempt Bonds, the sequester reduction percentage applied to the payments made to issuers of direct pay bonds in fiscal year 2018 will be 6.6 percent. This percentage...more

Clark Hill PLC

IRS Publishes Final Issue Price Rules for Tax-Exempt Municipal Bond Offerings

Clark Hill PLC on

The Internal Revenue Service ("IRS") has approved final issue price regulations under Section 148 of the Internal Revenue Code, effective for bond offerings sold on or after June 7, 2017. The new definition of issue price...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

Orrick, Herrington & Sutcliffe LLP

Final Treasury Regulations Defining Issue Price

For a variety of reasons related to arbitrage, it often is important to identify the "issue price" of tax-exempt bonds with precision and certainty. Existing Treasury Regulations generally allow the "issue price" of publicly...more

Bracewell LLP

Final Issue Price Regulations Significantly Change Current Rules

Bracewell LLP on

On December 9, 2016, the IRS released final Treasury Regulations (the “Final Regulations”) relating to the “issue price” of tax-exempt bonds for purposes of arbitrage investment restrictions. Although, on balance, an...more

Bracewell LLP

IRS Issues Final Regulations Regarding Allocation of Bond Proceeds to Mixed-Use Projects; SLGS Window Reopens

Bracewell LLP on

On October 26, 2015, the IRS released final regulations (the “Final Regulations”) regarding allocation and accounting rules for purposes of the private activity bond restrictions applicable to tax-exempt bonds issued by state...more

Bracewell LLP

FY 2016 Sequestration Reduction Percentage for Direct Pay Tax Credit Bonds Set at 6.8 Percent

Bracewell LLP on

According to an update released by The IRS Office of Tax Exempt Bonds (TEB), the sequester reduction percentage applied to the payments made to issuers of direct pay bonds in FY 2016 will be 6.8 percent. This percentage will...more

33 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide