Web(i) Recovery of overpayment of rebate. (1) In general. (2) Limitations on recovery. (3) Time and manner for requesting refund. (j) Examples. (k) Bona fide debt service fund exception. § 1.148-4 Yield on an issue of bonds. (a) In general. (b) Computing yield on a … WebSep 26, 2007 · Section 1.148-3 (i) (1) of the Existing Regulations provides that an issuer may recover an overpayment of arbitrage rebate with respect to an issue of tax-exempt bonds if the issuer establishes to the satisfaction of the IRS Commissioner that an …
H.R.2576 - 118th Congress (2024-2024): To amend the Securities …
WebAn issue (other than a refunding issue) qualifies for the small issuer exception only if the issuer reasonably expects, as of the issue date, that the aggregate face amount of all tax-exempt bonds (other than private activity bonds) issued by it during that calendar year will not exceed $5,000,000; or the aggregate face amount of all tax-exempt … WebComputation of Arbitrage Rebate; Exceptions. Small issuer exception. 6-month exception. 18-month exception. 2-year exception. Exception for certain investments. Penalty in Lieu … photogrammetry software 3df zephyr
BEYOND THE CLOSING Guide to Post-Issuance Compliance
WebAn issue is an issue of private activity bonds (and not tax-exempt governmental bonds) if the issuer reasonably expects, on the issue date, that either: 1) the private business use test and the private payment or security test will be met; or 2) the private loan financing test will be met. Private Business Use Test: More than 10% of the proceeds Webfollowing exceptions: o small issuer o bona fide debt service fund o 6-month spending o 18-month spending o 2-year construction spending • Given a set of facts, complete the … WebAn issuer may apply the arbitrage rebate requirement to an issue that otherwise satisfies a spending exception. If an issuer elects to pay penalty in lieu of rebate under the 2-year exception, however, the issuer must apply those penalty provisions. (b) Rules applicable for all spending exceptions. photogrammetry photo sets