Archives: Remedial Action

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In the New World of the Final Allocation and Accounting Regulations, What Is Left of “Final Allocations”?

Since the final allocation and accounting regulations (“Allocation Regs”) were published on October 27, 2015, they have been a recurring topic of this blog (see here, here, here, and here).  One question yet to be addressed is what, if anything, is the continuing importance of a “final allocation” of tax-favored bond proceeds in the wake … Continue Reading

Eliminating the Vice of Premature Virtue – Anticipatory Remedial Action

Last week Mike Cullers summarized Treasury’s latest addition to the final private activity bond regulations – the “Allocation and Accounting Regulations” — which were published earlier that week (LINK).   This week we begin to focus on the details of those Regulations, beginning with the much appreciated “anticipatory remedial action” rule (the “ARA Rule”). [1] Prior … Continue Reading
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