Header graphic for print
Public Finance Matters Updates on recent public finance and municipal bond developments

Tag Archives: arbitrage

Treasury/IRS Provide Early Holiday Present: Final “Issue Price” Regulations Released

Posted in Tax/arbitrage

By CHRISTIE MARTIN and MAXWELL D. SOLET After two sets of proposed regulations, Treasury and IRS have now released final regulations on the definition of “issue price” for purposes of arbitrage investment restrictions that apply to tax-advantaged bonds (the “Final Regulations”) and it appears that the third time’s the charm. Practitioners are particularly praising the… Continue Reading

IRS Announces Closing Agreement Process for At-Risk Student Loan Bonds

Posted in Tax/arbitrage

The IRS has announced the procedures, and settlement cost methodology, for issuers seeking to preserve the tax-exemption of those student loan bonds that are at risk of being declared taxable due to the issuer’s attempted compliance with arbitrage restrictions using a loan-swapping technique that the IRS has determined is ineffective.  The closing agreement arrangements, which are… Continue Reading

IRS Audit of CCRC Bonds’ Tax-Exemption Resolved

Posted in Tax/arbitrage

  BY MIKE SOLET The much-publicized IRS audit of the Mission Ridge project in Montana has been resolved favorably, with the IRS concluding that the bonds are not “arbitrage bonds” and remain tax-exempt.  The IRS audit had focused on CCRC entrance fees and the technical issue of whether the CCRC erred in not treating its accumulated… Continue Reading