Public Finance Tax

Month: October 2013

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    Yield and Valuation of Investments (Treas. Reg. § 1.148-5)

    General: The term “arbitrage bond” for purposes of I.R.C. § 148 means any bond issued as part of an issue any portion of the proceeds of which are reasonably expected (at the time of issuance of the bond) to be used directly or indirectly (1) to acquire higher yielding investments, or (2) to replace funds […] READ MORE

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    Tender Option Bond Programs

    General Overview A TOB program is typically initiated by an institutional investor, such as a mutual fund, and is implemented by a bank. The bank provides credit enhancement and remarketing services for the short maturity variable rate securities that represent the initiating investor’s leverage. The initiating investor uses this borrowed capital to purchase a longer […] READ MORE

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    Acquisition of Existing Property (I.R.C. § 147(d))

    General Overview: Under Section 147(d), net proceeds of private activity bonds cannot be used to acquire property unless the “first use” of the property is pursuant to the acquisition, unless a qualifying amount of rehabilitation expenditures is made in connection with the acquisition.  See PLR 8929073. The restriction under Section 147(d) does not apply to […] READ MORE

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Tracking select public finance tax developments since 2009.

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