Comments
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.…
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).
Input on Municipal Disclosure Guidance
NABL is again considering seeking additional guidance on municipal disclosure obligations and updates to the U.S. Securities and Exchange Commission’s (SEC’s) 1994 Interpretive Release.
Requests for 2023-2024 IRS Priority Guidance Plan
Requested items for inclusion on the Internal Revenue Service’s (IRS) 2023-2024 Priority Guidance Plan.
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.”
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…
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…
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…
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.
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 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…