Recommendations for Modifying IRS Treatment of Research Agreements as Private Use (per Rev. Proc. 97-14)

Discussion of guidance recommendations for a modification of Revenue Procedure 97-14 to clarify that research agreements containing “Bayh-Dole Rights” do not result in private business use, as defined in Section 141 of the Internal Revenue Code and Treasury Regulation § 1.141-3, of tax-exempt bond financed facilities and to expand the second safe harbor to include…