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.


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LIBOR Transition Project

On October 9, 2019, IRS and Treasury released proposed regulations that provide guidance on the tax consequences of the transition away from LIBOR. Rev. Proc. 2020-44, released October 9, 2020, provided interim guidance in advance of finalizing the proposed regulations. On December 30, 2021, final regulations were released. Now the NABL Tax Law Committee is working to draft comments to address unresolved points from the final rule.  

Status: In process and near completion.

Tax Due Diligence Best Practices

A group of NABL Tax Law Committee are producing a three tax due diligence best practice guides on governmental bonds, exempt facility bonds, and 501(c)(3) bonds.   

Status: In process.

Qualified Broadband Bonds Comments

The Infrastructure Investment and Jobs Act (Pub. L. 117-58) expands Internal Revenue Code Section 142(a) to provide a new category of exempt facility bonds for the financing of “qualified broadband projects.” As written, there are questions regarding the ability to issue bonds to meet the stated requirements. At a NABL virtual roundtable discussion in January to discuss the new legislation, it was determined that guidance would be helpful to address certain questions and gaps in the legislation. A working group is being formed to draft and finalize the comments. Email Matthias Edrich ( for more details and to express interest in joining. 

NABL/GFOA Post-Issuance Compliance Checklist

NABL will work with the Government Finance Officers Association to review and update our joint Post-Issuance Compliance Checklist from 2016. Email Brian Egan ( for more details and to express interest in joining.

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June 24, 2022: NABL Request for Guidance on Carbon Capture Bonds-- IRC Section 142(o)

June 2, 2022: NABL Comments in Response to Request for Input on IRS Priority Guidance Plan for 2023

February 14, 2022: Issuers Request for Permanent Telephonic TEFRA Hearings

September 7, 2021: Letter to Congress on Budget Reconciliation

August 30, 2021: Letter to IRS Requesting Extension of Affordable Housing Test Relief

August 23, 2021: Letter to Treasury on TEFRA Telephonic Hearing Extension

August 11, 2021: Letter to Treasury on Revenue Procedure 2018-58

March 1, 2021: Letter to IRS on Private Letter Ruling Fee Increase

February 10, 2021: Letter to Congressional Research Service on Private Activity Bonds

October 2, 2020: TEFRA Telephonic Hearing Extension

September 29, 2020: Updates to Instructions to IRS Form 8038 and 8038-G

  • Find the marked copy of Form 8038 Instructions here.
  • Find the marked copy of Form 8038-G Instructions here.

September 18, 2020: IRS User Fees for Private Letter Rulings Regarding Tax-Exempt Bonds

July 22, 2020: Comments to IRS Priority Guidance Plan for FY 2020-21

April 9, 2020: Letter to Congress and Treasury as they continue to develop additional legislative and regulatory initiatives to provide economic stimulus and fiscal relief as a result of the economic impact of the COVID-19 pandemic.

March 25, 2020: Letter to Treasury requesting certain immediate relief for issuers

March 22, 2020: Letter to Congress/Treasury on COVID-19 Economic Stimulus Package 

November 25, 2019: LIBOR Comments

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