The New Phonebooks are Here!
New private letter rulings are here! The IRS released two new private letter rulings. Neither of them is earth-shattering. In the first, PLR 201445002, the IRS ruled that an authority created by a...
View ArticleArbitrage Rebate Refunds – Final Regulations
The IRS published final regulations on November 13, 2014, governing claims for refund of arbitrage rebate overpayments. The final regulations do three main things. First, they set a two-year statute...
View Article50% Rebate Penalty – Will It Ever Be Waived on Audit?
At least from this practitioner’s perspective, in the earlier days of IRS bond audits, there were substantial inconsistencies in IRS practices. Different documents were requested by the examining...
View ArticleA Summary of the Final Regulations on Non-Issue Price Arbitrage Restrictions
On July 18, 2016, the Treasury Department published final regulations on non-issue price arbitrage restrictions (the “Final Regulations”) in the Federal Register. The Final Regulations finalize...
View ArticleFinal Arbitrage Regulations Require “Look Through” to a Grantee’s Use of Bond...
From time to time, issuers will use bond proceeds to make grants to accomplish a governmental purpose. For example, a State bond issuer may make grants to various counties and cities to help with the...
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How did arbitrage “rebate” get its name?
‘I meant by “impenetrability” that we’ve had enough of that subject, and it would be just as well if you’d mention what you mean to do next, as I suppose you don’t mean to stop here all the rest of...
View ArticleA Requiem for Reasonable Expectations
The “reasonable expectations” approach to determining the issue price of a tax-advantaged bond[1] has been the law since 1989. On June 7, it is scheduled to join Betamax tapes and parachute pants as...
View ArticleClik here to view.
Someone Left the Crayons Out, and Now the Tax Lawyers Are Drawing Pictures...
Timing, as they say, is everything. The tax-exempt bond rules are full of deadlines and sunsets, both before and after the issue date and before and after the project is finished. Click above for a...
View ArticleClik here to view.
Talking about The Thing
Yes, The Thing touches everything. COVID-19 affects the muni bond world in some fairly obvious ways. The general mandate is “everybody do less.” Decreasing activity in general translates to decreased...
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IRS Extends 8038 Filing, Rebate Payment, and Other Deadlines to July 15, 2020
The IRS has extended to July 15, 2020 the deadline for certain time-sensitive actions for tax-exempt bonds, including filing Form 8038 and paying rebate, if the deadline originally fell on or after...
View ArticleThe New Phonebooks are Here!
New private letter rulings are here! The IRS released two new private letter rulings. Neither of them is earth-shattering. In the first, PLR 201445002, the IRS ruled that an authority created by a...
View ArticleArbitrage Rebate Refunds – Final Regulations
The IRS published final regulations on November 13, 2014, governing claims for refund of arbitrage rebate overpayments. The final regulations do three main things. First, they set a two-year statute...
View Article50% Rebate Penalty – Will It Ever Be Waived on Audit?
At least from this practitioner’s perspective, in the earlier days of IRS bond audits, there were substantial inconsistencies in IRS practices. Different documents were requested by the examining...
View ArticleA Summary of the Final Regulations on Non-Issue Price Arbitrage Restrictions
On July 18, 2016, the Treasury Department published final regulations on non-issue price arbitrage restrictions (the “Final Regulations”) in the Federal Register. The Final Regulations finalize...
View ArticleFinal Arbitrage Regulations Require “Look Through” to a Grantee’s Use of Bond...
From time to time, issuers will use bond proceeds to make grants to accomplish a governmental purpose. For example, a State bond issuer may make grants to various counties and cities to help with the...
View ArticleClik here to view.
How did arbitrage “rebate” get its name?
‘I meant by “impenetrability” that we’ve had enough of that subject, and it would be just as well if you’d mention what you mean to do next, as I suppose you don’t mean to stop here all the rest of...
View ArticleA Requiem for Reasonable Expectations
The “reasonable expectations” approach to determining the issue price of a tax-advantaged bond[1] has been the law since 1989. On June 7, it is scheduled to join Betamax tapes and parachute pants as...
View ArticleClik here to view.
Someone Left the Crayons Out, and Now the Tax Lawyers Are Drawing Pictures...
Timing, as they say, is everything. The tax-exempt bond rules are full of deadlines and sunsets, both before and after the issue date and before and after the project is finished. Click above for a...
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