The Public Finance Tax Blog

This blog is written by the public finance tax group of Squire Patton Boggs. We are one of the largest and most experienced public finance tax groups in the country, with six tax attorneys who devote themselves exclusively to this area and collectively possess more than 100 years of experience in handling the federal tax aspects of public finance, and several additional tax attorneys who work in public finance tax and other areas as well.

Treasury Clarifies Effective Date Of Revised Definition Of ‘Available Amount’

On July 18, 2016, the Treasury Department published final regulations on non-issue price arbitrage restrictions (the “Final Regulations”).  A copy of the Final Regulations is available here.  Since that time, the mid-afternoon naps of issuers, tax lawyers, and possibly Sean from Portlandia have been improved by reading my “comprehensive” blog post on the Final Regulations.… Read more

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PLR 201726007 – Insights Into The Facts & Circumstances Test For Private Business Use After Rev. Proc. 2017-13

The IRS recently released PLR 201726007, the first private letter ruling to interpret the revised management contract safe harbor in Rev. Proc. 2017-13. On one level, the PLR is quite straightforward – it concludes that a teaching agreement between a hospital and a school to provide clinical practice for pharmacy students does not result in private business use.… Read more

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The Constitution Prevails As The Political Subdivision Regulatory Project Gets Trumped

July 7, 2017 witnessed a once-in-a-career moment for any tax practitioner.  On that date, the Treasury Department released Notice 2017-38, which acknowledged that eight regulatory projects are unduly burdensome and should be reconsidered for modification or repeal – a rare display of administrative modesty.  Included in the list of burdensome regulations are the proposed regulations that would re-define the term “political subdivision” for purposes of which entities can issue tax-exempt bonds under Section 103 of the Internal Revenue Code (the “Political Subdivision Proposed Regulations,” which we have previously analyzed here, here, here, here, here, and here).… Read more

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