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
In 1978, responding to attempts by issuers and borrowers to set aside funds for investment above the yield on outstanding tax-exempt bonds, the IRS published regulations seeking to shut down the practice of establishing...more
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
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