WebThe small issuer exception to the Rebate Rule may also apply. Ordinarily, this rule applies if the governmental entity reasonably expects, as of the issue date, that it will not issue during the calendar year more than an aggregate face amount of tax-exempt governmental bonds of $5 million, or the issuer does WebJul 22, 2016 · Small Issuer Exception to Rebate Requirement – Pooled Bonds (Regulation 1.148-8) The provision in the Prior Regulations that permits a pool bond issuer to ignore its pool bond issue in computing whether it has exceeded its $5 million limit for purposes of the small issuer rebate exception is eliminated in the Final Regulations.
Arbitrage Rebate 101
WebFeb 3, 2024 · However, if an issuer can satisfy any of the 4 rebate exceptions described below, the issuer is permitted to keep any positive arbitrage: Small Issuer Exception – applies if the issuer (and any subordinate entity, like a district) issues less than $5 million of tax-exempt bonds in a calendar year. The exception is increased to $15 million if ... WebCreated Date: 5/17/2024 3:52:34 PM iphone x ray vision
Tax-Exempt Bond Tools for Governments Facing Cash Flow …
WebSection 1.148–8 (d) is revised to read as follows:§1.148–8 Small Issuer Exception to Rebate Requirement.* * * * * (d) Pooled financings — treatment of conduit borrowers. Pooled financings may involve proceeds of governmental bonds or certain types of private activity bonds. Related to Pooled financings 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 … 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 iphone x r size