On June 14, 2023, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) under two novel provisions of the Inflation Reduction Act of 2022 (the “IRA”) designed to promote capital investment in renewable...more
Between April 2009 and December 31, 2010, state and local governments borrowed more than $181 billion through the issuance of 2,275 separate issues of Build America Bonds, which were authorized under the federal American...more
Historically, only taxpaying entities could take advantage of federal tax credits for renewable energy and other qualifying projects. Tax-exempt entities, such as municipal utilities and rural electrical cooperatives, as well...more
The Internal Revenue Service (“IRS”) has an active program of auditing tax-exempt bonds, and conducts those audits in a manner intended to ensure confidential information is not improperly disclosed. As part of those efforts,...more
In November, the bipartisan Infrastructure Investment and Jobs Act (the “Act”) was enacted into law. In addition to reauthorizing existing programs, the Act adds $550 billion in funding for new infrastructure investments,...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
12/13/2018
/ Airports ,
Bonds ,
Equity ,
IRS ,
Private Letter Rulings ,
Project Finance ,
Public Finance ,
Real Estate Development ,
Retail Market ,
Tax-Exempt Bonds ,
Wine & Alcohol
On November 2, 2017, the Republican leadership of the United States House of Representatives introduced the Tax Cuts and Jobs Act (the “Bill”). The Bill would make significant changes to tax rules that apply to tax-exempt...more
11/6/2017
/ 501(c)(3) ,
Alternative Minimum Tax ,
Bonds ,
Government Bonds ,
Municipal Bonds ,
Proposed Legislation ,
Public Projects ,
State and Local Government ,
Tax Credits ,
Tax Reform ,
Tax-Exempt Bonds ,
Trump Administration
New tax rules relating to establishing the issue price of publicly offered tax-exempt bonds become effective soon. This outline describes the new issue price rules, provides a high-level strategic analysis to help guide a...more
Introduction to Tax for Public Finance -
• What is the tax-exemption for state and local bonds?
• Types of tax-exempt bonds
• Overview of federal income tax requirements...
...more
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