This Committee advises the Board regarding developments in federal tax law (including developments pertaining to the US Department of Treasury and the Internal Revenue Service) and prepares on behalf of NABL, at the direction of the Board, comment letters, informative memoranda, and other written materials pertaining to tax law.


 

(617) 348-1769
Brian P. Teaff,Vice-Chair
(713) 221-1367
Matthias M. Edrich,Board Liaison
(303) 292-7887

Letter to Congressional Research Service on Private Activity Bonds

The Congressional Research Service released a report dated July 13, 2018 (Private Activity Bonds: An Introduction), which purports to provide a history of tax-exempt private activity bonds and takes a generally negative view of them. NABL leadership and tax-exempt bond community members have identified a number of areas in this report that could be made more precise and accurate. NABL leadership has met with the CRS staff regarding the report and offered to provide suggestions for improvement.

Status: The paper is in the final stages.

Cinderella Bonds

With the demise of advance refunding bonds, issuers have looked for ways to take advantage of historically low interest rates.  One structure that seems to be gaining traction is a Cinderella bond structure in which bonds are issued on a taxable basis and “convert” to tax exempt at some future date.  The project involves making recommendations regarding pricing safe harbors for Cinderella bonds. 

Status: The project is underway but on temporary hold.

Expanding the Floating Equity Approach of PLR 201847001

On November 23, 2018, the IRS released a private letter ruling allowing an issuer to use a floating equity approach to address compliance with the rule in Section 147(e) of the Code that prohibits the use of proceeds of tax-exempt private activity bonds for a business the principal purpose of which is the sale of alcoholic beverages for consumption off premises.  NABL believes that additional guidance to expand the approach in this PLR to other areas of the law governing private activity bonds might be helpful.  

Status: The project has commenced, but the Committee is still seeking volunteers to assist with this request for expanded guidance.

To access all projects, visit our Research tab.