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

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.

Suggestions to IRS Regarding Relief from Certain Tax Requirements in Times of Emergency

This project is a request to extend relief provided in Notice 2020-53 for 142(d) transition period and rehab expenditure period, as well as requesting to expand the list of “time-sensitive acts” in Rev. Proc. 2018-58 to include additional tax-exempt bond compliance actions that can be suspended upon IRS guidance in connection with a federally declared disaster or terroristic or military action.

 

Status: A working group of NABL volunteers has been assembled and the project is underway.

To access all projects, visit our Research tab.