Tax Law Committee

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.

Christie Lombard Martin,Chair

(617) 348-1769

Brian P. Teaff,Vice-Chair

(713) 221-1367

John W. Hutchinson,Board Liaison

(212) 940-3141

Current and Ongoing Projects
Past Projects

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 (matthias.edrich@kutakrock.com) 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 (began@nabl.org) for more details and to express interest in joining.

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