This is Part 2. Go here for Part 1. When we left off, the New Hampshire Health and Education Facilities Authority had shown the IRS Tax-Exempt Bond Division (“TEB”) its Old Man in the Mountain face on June 27, 2013, after TEB insisted that the Authority admit that it violated the tax-exempt bond rules before it would allow … Continue Reading
The IRS Appeals office has dropped the examination of nine student loan bond issues of the New Hampshire Health and Education Facilities Authority. The examination had begun after the Authority entered but then withdrew from the IRS specialized “voluntary closing agreement program” for student loan bonds. The IRS created this targeted VCAP in 2012 as a standalone … Continue Reading
A Diminished Market, But Still Functioning in More Limited Ways The IRS issued Notice 2015-78 [link] (“2015 Student Loan Notice” or “Notice”) on November 13, 2015. To some, it was unclear why the IRS would bother issuing any guidance for a narrow type of tax-exempt bond that is issued in a vastly diminished volume as … Continue Reading
Back in the 1980’s and 1990’s and even into the beginning of this century, student loan bonds were issued with great regularity and in a large dollar volume. Then a single event in 2010 (described below) dramatically diminished the issuance of new money student loan bonds. Given that diminished flow of student loan financings, why … Continue Reading