• Comments

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
Interior of the U.S. Supreme Court building in Washington, D.C. Source: Phil Roeder via Wikimedia Commons
  • 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.…

  • Comments

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).

  • Comments

Requests for 2023-2024 IRS Priority Guidance Plan

Requested items for inclusion on the Internal Revenue Service’s (IRS) 2023-2024 Priority Guidance Plan.

  • Comments

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.”

  • 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…

  • Comments

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

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…