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Comments to IRS on Final Rule on Private Activity Bonds (PABs)
Comments to the Department of the Treasury regarding final regulations published on October 27, 2015, in the Federal Register relating to the definition “private activity bonds” (the “Final Regulations”).
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September 26, 2018
Johanna Som de Cerff
Senior Technician Reviewer
Office of Associate Chief Counsel
Internal Revenue Service
1111 Constitution Ave NW Rm 4013
Washington, DC 20224-0001
John J. Cross III
Associate Tax Legislative Counsel
Department of the Treasury
Office of Tax Policy
1500 Pennsylvania Ave NW, Rm 3049
Washington, DC 20220-0001
RE: Comments Regarding Final Regulations on Allocation and Accounting and Certain Other Matters
Ladies and Gentlemen:
The National Association of Bond Lawyers (NABL) respectfully submits the enclosed comments to the Department of the Treasury regarding final regulations published on October 27, 2015, in the Federal Register relating to the definition “private activity bonds” (the “Final Regulations”).
The enclosed comments were prepared by a NABL Working Group, comprising the individuals listed in Exhibit B and approved by the NABL Board of Directors. NABL exists to promote the integrity of the municipal securities market by advancing the understanding of and compliance with the law affecting public
finance. We respectfully provide this submission in furtherance of that mission.
Thank you in advance for your consideration of these comments.
Sincerely,
Alexandra M. MacLennan
Enclosure
Select References
- [TD 9741] Internal Revenue Service (IRS) and Treasury Department Final Rule / Correcting Amendment on “General Allocation and Accounting Regulations Under Section 141; Remedial Actions for Tax-Exempt Bonds; Correction”
- Sec. 146 of the Internal Revenue Code (IRC)
- Treas. Reg. § 1.141-6
- Treas. Reg. § 1.141-13
- Treas. Reg. § 1.148-6