Thursday, December 12, 2013
Ellen P. Aprill (Loyola-L.A.), Municipal Bonds and Accountability to the General Electorate, 141 Tax Notes 547 (Nov. 4, 2013):
A recent IRS technical advice memorandum [127670-12] denied tax-exempt status to bonds of a development district on the grounds that the district was not “inherently accountable, directly or indirectly, to a general electorate.” This short piece reviews applicable law and private letter rulings to argue that this position represents an unprecedented change in applicable standards. Such a change should be introduced as a proposed regulation with notice-and-comment.
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