WebArbitrage Rebate Exceptions There are two major exceptions to arbitrage rebate: size-based and time-based. Generally, an issue is exempt from arbitrage rebate under the small issuer exception if the issuer has governmental taxing powers and reasonably expects to issue no more than $5,000,000 face amount of tax-exempt bonds WebComputation of Arbitrage Rebate; Exceptions. Small issuer exception. 6-month exception. 18-month exception. 2-year exception. Exception for certain investments. Penalty in Lieu …
IRS Arbitrage and Rebate Rules Return to the Forefront
Web§ 1.148-8 Small issuer exception to rebate requirement. (a) Scope. Under section 148(f)(4)(D), bonds issued to finance governmental activities of certain small issuers are treated as meeting the arbitrage rebate requirement of section 148(f)(2) (the “small … If the issuer makes the election under this paragraph (b)(6)(ii), the rebate … 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 … great fire of london lessons
eCFR :: 26 CFR 1.148-0 -- Scope and table of contents.
Webwithin a specific exception. One of the exceptions to rebate generally utilized by the school districts is provided in section 148(f)(4)(D). This is referred to as the “small issuer exception.” The small issuer exception to paying rebate is available to an issuer if the aggregate amount of all tax-exempt bonds issued by the issuer in the ... 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 8, 1997 · ( 6) Small issuer exception to rebate requirement for conduit borrowers of pooled financings. Section 1.148-8 (d) applies to bonds issued after May 17, 2006. ( l) Permissive application of certain arbitrage updates - ( 1) In general. flirty chin touch