WASHINGTON – The National Association of Bond Lawyers wants the Treasury Department and Internal Revenue Service to revise the management contract guidance released in August, which it says is confusing and could limit the usefulness of safe harbors in short-term contacts.

In a five-page comment letter sent to Treasury Associate Tax Legislative Counsel John Cross and IRS Office of the Chief Counsel Branch Chief Vicki Tsilas, NABL President Cliff Gerber said that the guidance in Rev. Proc. 2016-44 creates "interpretative gaps" that could limit the usefulness of the safe harbor guidance and may be inconsistently applied by IRS examiners of management contract private business use rules.

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