Notice 2014-67

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Following Revenue Procedure 2016-44, is there still a ‘facts and circumstances’ test for private business use?

As we have discussed in previous posts (here), most practitioners treat a management contract for services at bond-financed property that does not fit within a safe harbor from private business use as giving rise to private business use of the bonds for tax purposes.  However, the Treasury Regulations provide that whether or not a management … Continue Reading

The Curious Case of Hospital Financings

There are few stereotypes more accurate than the stereotype that tax lawyers appreciate order, continuity, familiarity, and certainty.  We are constantly trying to fit a particular fact pattern nicely and neatly into guidance prescribed by the IRS. This is especially true in determining whether a management contract under which a service provider operates a business … Continue Reading

NABL Comments on Notice 2014-67

On January 22, 2015, the National Association of Bond Lawyers submitted comments on Notice 2014-67 to the IRS. For those of you who like acronyms and defined terms, we’ll call these the “NABL” “Comments” on the “Notice,” and we’ll let you guess what “IRS” stands for. The first part of the Comments focuses on Accountable … Continue Reading