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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

Tax Relief for Replacing LIBOR in Tax-Exempt Debt and Swaps

Many tax-exempt bonds and related hedges, such as interest rate swaps ("Exempt Instruments"), use a LIBOR-based interest rate. LIBOR is going away, and existing Exempt Instruments are going to have to be modified to replace...more

IRS Releases Final TEFRA Regulations

On December 28, 2018, the U.S. Department of the Treasury released final regulations (the “Final TEFRA Regulations”) regarding the requirements for public notice, hearing, and approval of qualified private activity bonds...more

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

Tax Issues When Fixing Rate and Fee Adjusters in Tax-Exempt Loans

The recently enacted reduction of the maximum federal corporate tax rate may trigger contractual provisions that provide for a significant increase in the interest rate on tax-exempt debt privately placed with a bank lender...more

IRS Releases New TEFRA Regulations

Last week, the IRS released proposed regulations (“Proposed Regulations”) relating to the so-called TEFRA public notice and approval requirement for private activity bonds. In general, the Proposed Regulations make it easier...more

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