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More thoughts on the BAB reissuance memo
  • Squire Patton Boggs
  • USA
  • March 19 2015

Riddle me this, Batman: To whom does this memo matter? Consequences to the State or Local Government Borrower Current vs. Advance Refundings As


We’re totally returning to total return swaps for a second consecutive post
  • Squire Patton Boggs
  • USA
  • January 22 2015

Last week we reported on recently released PLR 201502008 (Jan. 9, 2015), which involved a total return swap (TRS) relating to an issue of tax-exempt


Camp tax reform proposal would greatly limit tax-exempt bonds and tax credit programs
  • Squire Patton Boggs
  • USA
  • March 19 2014

Representative Dave Camp (R-MI), Chairman of the House Ways & Means Committee, recently released a comprehensive tax reform proposal (Camp Proposal


EBTs - loans
  • Squire Patton Boggs
  • United Kingdom
  • November 30 2012

The recent case of Murray Group Holdings Limited v HMRC TC 2372 concerned the tax implications of a loan to an employee from an employee benefit trust


Bah. Humbug. How the IRS took away direct subsidies from defeased BABs
  • Squire Patton Boggs
  • USA
  • December 23 2014

Earlier this year, we wrote about issuers that are weary of losing interest subsidies to sequestration and that have paid off their direct pay bonds


Why would the IRS bother to issue a ruling about student loan bonds last week? What did the ruling tell us?
  • Squire Patton Boggs
  • USA
  • November 26 2014

Back in the 1980's and 1990's and even into the beginning of this century, student loan bonds were issued with great regularity and in a large dollar


Republicans to select chair of ways and means, IRS to discuss proposed regulations on MMFs
  • Squire Patton Boggs
  • USA
  • November 17 2014

As previously reported, lawmakers are expected to continue debate on tax extenders legislation. While many suspect that the end result will be a


Regulations regarding Shenzhen Qianhai Zone and the treatment under CEPA
  • Squire Patton Boggs
  • China, Hong Kong
  • September 10 2012

New cooperation zone to strengthen collaboration between Hong Kong, Shenzhen and the Pearl River Delta


IRS enforcement
  • Squire Patton Boggs
  • USA
  • January 14 2013

The IRS will continue its focus on the determination of the "issue price" of bonds (i.e., the correct resale price of the bonds). In recent interviews


Tax legislation
  • Squire Patton Boggs
  • USA
  • January 14 2013

The key issue in Congress is how broader tax reform efforts may impact the federal subsidy of state and local bonds. For example, last year the President