Orrick Tax Talk 12 - Allocation of Bond Proceeds and Floating Equity
Certain limitations exist with respect to private business use in tax-exempt financed facilities for both governmental and 501(c)(3) organizations. However, the Treasury Regulations also allow equity (proceeds other than proceed of a tax-exempt bond) in a project to reduce the applicable private business use. The rules, particularly relating to timing and to the definition of a “mixed use project”, are rigid and must be carefully applied. In this video, Larry and Ed review the rules relating to the application of “floating equity”. Understanding these rules will permit an organization to use equity in a smarter way to eliminate or negate private business use in within a mixed use project.
Other Tax Talk Videos
1. The ABC’s of Governmental Bonds
2. The ABC’s of 501(c)(3) Bonds
3. Private Business Use
4. Private Payments
5. Management Contracts (video removed – see video #13)
6. Sponsored Research Contracts
7. Private Activity Bonds
8. Tax Credit Bonds (video removed as tax credit bonds can no longer be issued)
9. Post-Issuance Tax Compliance
10. Change in Use/VCAP
11. IRS Audits
12. Allocation of Bond Proceeds and Floating Equity
13. Management Contracts – New 2017 Rules
