Post-Issuance Compliance

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How to Appeal Adverse Determinations from the IRS for Tax-Advantaged Bonds: New Guidance

The IRS has had a busy start to 2021! Guidance continues to pour forth as the change in Administration approaches. On January 4, the IRS released Revenue Procedure 2021-10, which provides issuers with updated procedures for obtaining review from the IRS Office of Appeals of proposed adverse determinations and rebate refund rejections by the IRS … Continue Reading

When Summer Reading and Public Finance Tax Intersect – Tax-Exempt Bonds, Pop Culture, and the Town of Windthorst

Early in my career, I learned to dread telling people that I was a lawyer because when I explained the niche practice of public finance tax law, their eyes started to get sleepy, then their eyes started to glaze over.  That was usually when I would blurt out “I help finance airports, hospitals, schools, and … Continue Reading

New “Remedial Actions” for BABs and other Direct Pay Bonds and Long-term Leases of Bond-financed Property

The IRS has given us new “remedial actions” for issuers of build America bonds and other direct pay bonds and for long-term leases of bond-financed property.  These new rules are in Revenue Procedure 2018-26, and you can apply them immediately to cure the violations that the Revenue Procedure covers. The beauty of the remedial action … Continue Reading

GFOA, NABL Release Post-Issuance Compliance Guidance

Just in time for the weekend, the Government Finance Officers Association (GFOA) and the National Association of Bond Lawyers (NABL) have each issued guidance for the development of post-issuance compliance procedures.  These procedures, which have long been encouraged by the IRS, are intended to facilitate compliance with the tax requirements applicable to tax-advantaged bonds after … Continue Reading
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