-
Subscribe
Subscribed
Already have a WordPress.com account? Log in now.
General Discussion: Treas. Reg. 1.150-1(d)(2)(iii) provides the following: (A) Refunding of a conduit financing issue by a conduit loan refunding issue. Except as provided in paragraph (d)(2)(iii)(B) of this section, the use of the proceeds of an issue that is used to refund an obligation that is a purpose investment (a conduit refunding issue) by […] READ MORE
Provisions Relevant to Commercial Paper Financings: Treas. Reg. 1.150-1(c)(4)(ii): Special rule to determine an “issue” of commercial paper Treas. Reg. 1.149(e)-1(e)(2)(ii): Special rule for determining what the issue of commercial paper is for purposes of information reporting Notice 2011-63: Discusses issue date determination for draw down loans and commercial paper (among others) Notice 2011-63: Under […] READ MORE
General Rules: The single issue determination addresses “substance over form” concerns. The issue determination is primarily relevant for determining whether bonds can be included in a single-yield computation. Bonds treated as part of a single issue under the test below will be so treated for purposes of the arbitrage rules and for purposes of the […] READ MORE
Issues Re: Draw-Down Loans: A. Information Reporting Requirements (1.149(e)-1(e)): Generally, interest on a bond is included in gross income unless proper information reporting is accomplished with respect to the issue of which the bond is a part. In a draw-down situation, the relevant question becomes: “what is the issue?” Under (e)(2), the issue is defined, […] READ MORE
IRS Guidance Regarding Issue Date for Draw Down Loans In November 2010, the IRS released Notice 2010-81 (the “Notice”) relating to “Build America Bonds and Other State and Local Bonds: Timing of Issuing Bonds.” The Notice divides the treatment of issue date for drawdown loan purposes into two categories: Draw down loans for which the […] READ MORE
General Rules: A refunding issue means an issue of obligations the proceeds of which are used to pay principal, interest or redemption price on another issue, including the issuance costs, accrued interest, capitalized interest on the refunding issue, a reserve or replacement fund or similar costs, if any, properly allocable to that refunding issue (Section […] READ MORE
Designed with WordPress
Public Finance Tax 