Naomi Jagoda has an article in The Bond Buyer ($) today with more commentary on Advice Memorandum 2014-009, where the IRS says that BABs don’t get the benefit of the rule that the defeasance of a “tax-exempt bond” doesn’t cause the bond to be reissued.

Note that others in the community are raising the same point that was raised in yesterday’s post: The Preamble of the reissuance regulations doesn’t really support the conclusion that the exception for tax-exempt bond defeasance escrows exists only to protect bondholders (not issuers) so that BABs shouldn’t be treated as “tax-exempt bonds” for this purpose.

Happy Holidays All!