IRS

The new guidance issued Wednesday under Notice 2019-39 covers, among other things, Tribal Economic Development Bonds and direct-pay Build America Bonds.

Calculating the remaining useful life of a port or airport facility can be problematic, but the IRS ruling released May 3 supports a simplified method of making this determination using the date of the new agreement as a starting point.

The Treasury and Internal Revenue Service sent the final regulation to the White House Office of Management and Budget over six weeks ago.

In the coming months bond lawyers expect numerous municipal governments to issue new bonds to support investments in Opportunity Zones.

The audit concluded a year and one day after the sports authority received a letter dated April 4, 2018, informing it that the tax-exempt status of the bonds was being examined.

A fourth audit in two months fuels the perception that the IRS has launched an enforcement initiative involving the island territory.

The clarification allows dozens of otherwise stalled housing projects around the nation to move ahead with financing that includes a combination of tax exempt multifamily PABs and the 4% federal housing tax credit.

The IRS audit of the Puerto Rico Municipal Finance Agency's $59 million in 2005 Series B Refunding Bonds is the third IRS audit of tax-advantaged bonds involving the commonwealth announced over the last six weeks.

If the IRS fails to provide a regulatory fix, two members of Congress may address the issue legislatively in bicameral affordable housing legislation that had wide bipartisan support in the last Congress.

Midwest Fertilizer Co. announced Monday it has settled with the IRS Office of Appeals an audit that originally disqualified the tax-exempt status of $1.259 billion of refunding bonds that will be used to help finance a fertilizer plant in Posey County, Indiana.

The $11 million in tax exempt bonds that financed the construction of the K through 6 school are being paid off by the owner of the apartment building developed on part of the 1.67-acre site.

Telley Meier, IRS field operations manager for the Indian Tribal Government/Tax Exempt Bonds office, advises bond attorneys to call the examination agent if they think an audit has been erroneously selected.

All four industry groups that submitted comments on the proposed rule requested a continuation of the practice that allows remarketing reissuances at a premium.

An easier procedure for declaring when a reissuance occurs is among NABL's recommendations.

The federal tax issue that is at stake in both audits involve the federal payments for the direct-pay subsidy.

The cap, repeal of which is a priority for state and local groups, will affect nearly 11 million taxpayers, an audit found.

“Major banking organizations have now used this abusive tax shelter scheme to illegally shelter well over $1 billion in taxable income,” said the letter by W. Mark Scott.

None of the 12 recommendations require congressional action and all are within the scope of the administrative powers of the IRS, according to NABL.

Libor based municipal debt stood at $47.6 billion at the end of 2018, or about 1.3% of the overall muni market.

The U.S. Court of Appeals for the District of Columbia ordered a district judge to review four documents totaling 16 pages in an IRS Office of Professional Responsibility case file for possible release under the federal Freedom of Information Act.