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Student Loan Refinance Programs (Notice 2024-32)
The Internal Revenue Service released Notice 2024-32 (the “Notice”) on March 25, 2024. The Notice relates primarily to qualified student loan bonds issued to fund refinance loans. Highlights include the following points: The Notice applies to bonds sold on or after April 15, 2024. An issuer may apply the Notice to bonds sold before April […] READ MORE
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State and Local Government Series Securities (SLGS)
Background State and Local Government Series (SLGS) securities are non-marketable Treasury securities that are available for purchase only by issuers of tax-advantaged securities. Tip for those who want to be real tax attorneys: Don’t spell SLGS with a small trailing “s.” Regulations Regulations concerning SLGS are found in Part 344 of Title 31 of the […] READ MORE
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Proposed I.R.C. 142(p) – Spaceports
Highlights regarding proposed spaceport legislation relating to exempt facility bonds READ MORE
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Volume Cap Matters
Summary of volume cap rules under Section 146 of the Internal Revenue Code of 1986 READ MORE
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ABA Comments on Proposed Private Activity Bond Regulations (May 26, 1995)
ABA comments are available online at https://www.taxnotes.com/research/federal/other-documents/public-comments-on-regulations/aba-tax-section-comments-on-proposed-regulations-on-private-activity/13b4m. Primary drafters were Tim Wolfe, William Loafman. Part III includes a useful discussion of private business use issues affecting development districts. Topics covered in this section: The comments address proposed regulations released December 29, 1994, available online at https://www.taxnotes.com/research/federal/proposed-regulations/new-rules-proposed-on-definition-of-private-activity-bonds/13s5r. READ MORE
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Inclusion in Gross Income of State Payments
Notice 2023-56: Federal Income Tax Consequences of Certain State Payments Provides rules the IRS will apply in determining the federal income tax consequences of refunds of state or local taxes and certain other payments made by state and local governments to individuals. Notice discusses general rule of Glenshaw Glass Co. regarding accession to wealth and […] READ MORE
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Exchange of Property (I.R.C. 1001)
For modifications of debt instruments, see Treas. Reg. § 1.1001-3. The page dedicated to this topic is here. For modifications of derivatives contracts, see Treas. Reg. § 1.1001-4 For transitions from IBORs, see Treas. Reg. § 1.1001-6 In the context of cryptocurrency protocol upgrades, see ILM 202316008 and Forst, McElroy and Dimon, “Blockchain Tax Principles […] READ MORE
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Exemption for Churches
For a basic discussion of 501(c)(3) matters relating to churches, see IRS Publication 1828. Declaration of Exemption I.R.C. § 508(a)(1) provides that an organization will not be treated as a section 501(c)(3) organization unless it has given notice to the Secretary that it is applying for recognition (i.e., by filing Form 1023 or Form 1023-EZ). […] READ MORE
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Qualified Broadband Projects (I.R.C. 142(n))
Fixed Wireless “Fixed, terrestrial broadband service” reference in I.R.C. 142(n)(1)(A) is not intended to exclude fixed wireless, according to the following report: https://wirelessestimator.com/articles/2021/senate-puts-it-in-writing-fiber-will-not-keep-wireless-from-benefitting-from-65-billion-broadband-bill/. “Senate puts it in writing: Fiber will not keep wireless from benefitting from $65 Billion broadband bill,” In Featured News by Wireless Estimator August 2, 2021. “The text states that broadband providers […] READ MORE
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General Opinion Matters
Jasper L. Cummings, Jr., “The Reliability of Tax Writings,” 177 Tax Notes Federal 1119 (Nov. 21, 2022): The author describes the ranking of tax writings based on his believe of the reliability of such writings. Ranked in order of reliability: (1) published guidance (T.D., Rev. Rul., Rev. Proc., Notices, Announcements, AoD – i.e., everything that […] READ MORE
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Qualified Management Contracts (Rev. Proc. 2017-13)
General References Rev. Proc. 97-13, as modified and amplified by Notice 2014-67, thanks to the publicfinancetaxblog. Rev. Proc. 2016-44, as revised on September 2, 2016 with the extended transition period. Modifies and supersedes Rev. Proc. 97-13 and Rev. Proc. 2001-39. Certain Private Letter Rulings and Advice Memorandums FSA 199932017 (Aug. 13, 1999): Whether a private […] READ MORE
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501(c)(3) Exempt Organization Rulings
This post lists exempt organization rulings relating to 501(c)(3) determinations or revocations. It is based on daily reports from CCH regarding ruling advance releases. The rulings illustrate various requirements for entities to be organized and operated as 501(c)(3) organizations. PLR 202221009 (Feb. 28, 2022): Purpose: Organization formed to develop, distribute, maintain open-source software and educational […] READ MORE
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TOPICS
- 1.1001-3 – Reissuance (2)
- 1.150-1 – Issue (6)
- 1.150-2 – Reimbursement (1)
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- 1221 – Capital Assets (1)
- 1273 – Determination of OID (2)
- 1275 – Special Rules (1)
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- 1394 – EZFBs (1)
- 1400 – Recovery Zone Bonds (1)
- 141 – Private Activity Tests (12)
- 1411 – NIIT (1)
- 142 (d) – Residential Rental (1)
- 142 – Exempt Facility Bonds (10)
- 143 – Mortgage Bonds (2)
- 144(a) – Small Issue Bonds (1)
- 144(b) – Student Loan Bonds (2)
- 145 – 501(c)(3) Bonds (3)
- 146 – Volume Cap (1)
- 147 – Other PABs Requirements (8)
- 148 – Arbitrage (29)
- 149 – Additional Rules (15)
- 150 – Definitions (2)
- 167 – Depreciation (Leases) (1)
- 168 – ACRS (1)
- 170 – Charitable Contributions (1)
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- 263 – Capital Expenditures (1)
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- 38 – Business Credits (1)
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- 45D – NMTC (1)
- 48 – ETC (1)
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- 529 – Tuition Programs (1)
- 54A – Tax Credit Bonds (1)
- 54AA – Build America Bonds (1)
- 54C – NCREBs (2)
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- 54E – QZABs (1)
- 54F – QSCBs (1)
- 55 – AMT (1)
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