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The purpose of Build America Bonds, commonly referred to as BABs, is to reduce the cost of borrowing for state and local government issuers and governmental agencies.Some traditionally tax-exempt issuers, such as private party issuers and 501(c)(3) organizations, were not eligible to use the Build America Bond program.
The provision denies tax-free treatment to certain spin-offs where either the distributing corporation or the controlled corporation is a "disqualified investment corporation", defined as having investment assets that are two-thirds or more (75 percent or more under a first-year transition rule) or the value of the corporation's total assets.
These rules prevent the avoidance of tax that might otherwise be available by characterizing the repayment as a capital gain, which is taxed at a lower rate, or by deferring the recognition of income until the bond is repaid at maturity. There are a number of exceptions to the original issue discount rule, including: Tax exempt obligations
For example, if a $5,000,000 annual tax increment is expected in a development, which would cover the financing costs of a $50,000,000 bond, only a $25,000,000 bond would be typically allowed. If the project is moderately successful, this would mean that a good portion of the expected annual tax revenues (in this case over $2,000,000) would be ...
Under Treasury Regulation section 1.141-2, an interest on a private activity bond is not excludable from gross income under section 103(a) of the Internal Revenue Code unless the bond is a qualified bond. Interest from private activity bonds became subject to the Alternative Minimum Tax after the Tax Reform Act of 1986. All things equal, yields ...
Revised IRS tax treatment of MLPs made the structure inefficient and infeasible, in light of the special tax that is levied on MLP owners who hold them in tax-deferred or exempt accounts such as 401(k)s, IRAs, and Roth IRAs. A more recent alternative called income depositary shares (IDS) has also failed to attract investor attention due to the ...
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On one end of the spectrum, a rigorous 'but for' test is employed, akin to those used in tax-exempt bond financing under federal tax law and in numerous state-taxable bond issuance programs. This test necessitates a demonstration that the business activity would not have occurred 'but for' the incentive. [ 19 ]