Bob Eidnier

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Our Holiday Gift to You – Rev. Proc. 97-13, as Modified and Amplified, In a Single Document

It has now been almost two months since the IRS issued Notice 2014-67 and the initial euphoria of tax lawyers across the country has begun to wane.  (To relive that excitement, please visit our posts of October 24, October 28 and November 5, reporting the new opportunities created by this Notice.)  Today we return to … Continue Reading

IRS Scrutiny Puts Prison Financings on Lockdown

Few prospects are more terrifying than either an audit by the Internal Revenue Service or anything involving prison.  Put the two together, and you not only have a nightmare worthy of Stephen King, you begin to appreciate how some issuers of tax-exempt bonds have been feeling recently. As reported in the press ($), several issuers … Continue Reading

The Tax Lawyer’s Swiss Army Knife – Allocating Bond Proceeds Away from the Flow of Funds

Treasury has provided a valuable yet often overlooked tool in the regulations governing the allocation of bond proceeds to expenditures under IRC §§141 and 148. Using this tool, you can allocate bond proceeds in a way that differs from the flow of funds. Treas. Reg. 1.148-6(d)(1)(iii) allows an issuer to allocate bond proceeds to expenditures … Continue Reading