The American Bar Association’s taxation section has sent the Treasury Department several suggestions it contends would simplify and make more flexible interim guidance for issuers, bondholders, and other market participants that want to strip the tax credits from tax-credit bonds.

However, the document, which was sent last week to Internal Revenue Service commissioner Doug Shulman, comes as issuance of tax-credit bonds has come to a virtual halt thanks to a recently enacted law that allows issuers of the four most popular tax-credit bonds to receive Build America Bond-style direct payments as subsidies instead of offering investors tax credits.

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