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Suggested Clarifications and Changes to IRS Rev. Proc. 97-13

Suggested clarifications and changes to the management contract safe harbors against private business use in Revenue Procedure 97-13. Revenue Procedure 97-13 provides both the general framework to evaluate whether a management contract gives rise to privatebusiness use for the purposes of the tax-exempt bond rules and several safe harbors. Increasingly, the safe harbors contained in…

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