• Comments

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…

  • 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.

  • Comments

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…


Multipurpose Issue Allocations in Refundings with “Debt Savings”

Member-exclusive virtual roundtable discussion on February 2, 2023 on multipurpose issue allocations in certain refundings.

Hudson Yards Rail Yards
  • Issue Briefs

Create a Direct Pay Bond Program

Equip our Communities with a New Financing Tool

Port of Seattle, Washington. Source: Wikimedia Commons
  • Issue Briefs

Expand Private Activity Bonds (PABs)

Expand Financing Options for Innovative and Critical Projects

Market tickertape. Source: Ahmad Ardity.
  • Issue Briefs

Restore Advance Refundings

Allow our Communities to Once again Refinance

Town of Galena, Illinois Source: Jasperdo via Flickr
  • Issue Briefs

Updating Bank Qualified Debt

Modernize Financing Options Available to Our Smallest Communities

  • Comments

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.

  • Comments

Response to IRS Requests on IRA Implementation

Comments submitted in response to a solicitation from the Internal Revenue Service (Notices 2022-49 and 2022-50) for requests for guidance relating to certain tax law changes enacted by the Inflation…

  • Comments

Comments to Final LIBOR Rule

Comments submitted in response to the final promulgation of Final Treasury Regulations §1.1001-6 and Final Amendments to §1.1275-2 relating to the transition from interbank offered rates (IBORs) to replacement benchmark…

The Internal Revenue Services (IRS) Building in Washington, D.C.
  • Issue Briefs

IRS Priority Guidance

View NABL request submissions for each year.