Comments
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Requests for 2024-2025 IRS Priority Guidance Plan
Requested items for inclusion on the Internal Revenue Service’s (IRS) 2024-2025 Priority Guidance Plan.
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Letter to Speaker Johnson
NABL congratulates the newly-elected Speaker and offers to serve as a resource on all things related to bond law.
![Interior of the U.S. Supreme Court building in Washington, D.C. Source: Phil Roeder via Wikimedia Commons](https://www.nabl.org/wp-content/uploads/2023/08/SCOTUS-Interior-1024x585.jpg)
Amicus Brief IMPA v. US (Cert)
A joint amicus brief submitted by NABL and several other municipal market groups in support of a petition for a writ of certiorari in the Indiana Municipal Power Agency v.…
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On Proposed Regulations for Section 6417 Elective Payments of Applicable Credits
Comment letter submitted to the Internal Revenue Service (IRS) in response to Proposed Regulations §§1.6417-1 through 1.6417-6 on Section 6417 Elective Payment of Applicable Credits (IRS REG – 101607-23).
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Requests for 2023-2024 IRS Priority Guidance Plan
Requested items for inclusion on the Internal Revenue Service’s (IRS) 2023-2024 Priority Guidance Plan.
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Joint Response to ABS Conflicts of Interests Proposal
Comments submitted by a NABL-led coalition in response to the SEC’s request for comments on its proposed rule “Prohibition Against Conflicts of Interest in Certain Securitizations.”
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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…
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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.
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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…
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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…
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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.
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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…