Orrick Tax Talk 10 - Change in Use/VCAP
In certain circumstances, an issuer or borrower of tax-exempt bonds may seek to change the use of bond financed property during the life of that property, which could include selling the property. This would constitute a “deliberate act” to move a bond finance property from compliant to non-compliant in relation to certain IRS rules. Certain “deliberate acts” are permitted, however, as long as the issuer or borrower takes advantage of certain self-help rules to help them fix the corresponding tax problem. Listen to this video to learn about self-help rules and the Voluntary Closing Agreement Program as related to change in use of tax-exempt bond financed property.
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
