RE: Proposed Regulations Concerning Guidance on Tax-Exempt Refunding Bonds and Allocation and Accounting Rules [REG-117298-21]

Dear Mr. Bessent, Mr. Kies, and Mr. Salinger:

The National Association of Bond Lawyers (“NABL”) respectfully submits the attached comments to the proposed regulations published in 91 Fed. Reg. 12118 (Mar. 12, 2026) titled “Guidance on Tax-Exempt Refunding Bonds.”  The comment focuses particularly on Paragraph 7 affecting the general allocation and accounting rules contained in Treas. Reg. § 1.148-6 (the “Proposed Regulations”).  The comments were prepared by a working group comprised of the individuals identified in the attachment to the comments and were approved by the NABL Board of Directors.  NABL respectfully requests to testify at a public hearing regarding the Proposed Regulations.  These comments provide an outline of NABL’s expected testimony.

NABL is a nonprofit organization and specialty bar association of approximately 2,500 lawyers whose purposes include, among other things, providing advice and comment at the federal, state, and local levels with respect to legislation affecting state and municipal obligations.  NABL believes that participating in the guidance process supports clarification of, and facilitates compliance with, tax laws and regulations, and would welcome the opportunity to discuss
these recommendations. 

Thank you in advance for your time and attention.  We look forward to hearing from you.

Best,

Matthias Edrich

President
National Association of Bond Lawyers

CC:

• Edward Killen, Commissioner, TE/GE, Internal Revenue Service
• Jeffrey Van Hove, Associate Chief Counsel, CC:FIP
• Vassiliki Tsilas, Deputy Associate Chief Counsel (Acting), CC:FIP
• Brian Choi, Office of Associate Chief Counsel, CC:FIP
• Zoran Stojanovic, Assistant to the Branch Chief, CC:FIP:B5