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
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