Suppl. Comments on IRS Notices 2022-49 and 2022-50
Follow up comments to a November 4, 2022 letter sent by NABL suggesting various areas of need for guidance relating to certain tax provisions enacted under the Inflation Reduction Act (IRA).
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Recent Comments
Request for Guidance On Qualified Broadband Bonds
Comments submitted to the Internal Revenue Service (IRS) requesting clarifying guidance pertaining to the recently enacted qualified broadband project bonds.
Declaration of Intent Requirement of Treasury Regulations § 1.150-2
Commentary sent to Treasury and the IRS describing the declaration of intent requirement for bond proceeds used to reimburse prior expenditures contained in Treasury Regulations § 1.150-2 and setting forth its historical background.
Issuer Letter on PAYGO Sequestration
On December 15, 2022, issuer representative groups of the Public Finance Network (PFN) sent a letter urging Congress to address pending Pay As You Go (“PAYGO”) scorecards before the end of the year.
Comments on Proposed SLGS Rule Changes
Response to proposed regulations from the Bureau of Fiscal Services (BFS) pertaining to the State and Local Government Series (“SLGS”) securities program.