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Howell and Christi A. Late last year the IRS said its initial fiscal focus involved potential arbitrage violations of Internal Revenue Code Section by the investment of bond proceeds in higher-yielding investments beyond the allowable temporary period under Treasury Regulation Treas.

At that time, the IRS said other priorities for tax compliance and enforcement involving municipal bonds would be released in quarterly updates on the webpage of the Tax Exempt and Government Entities Division-Compliance Programs and Priorities. The IRS also said Monday that it would continue its fiscal IRS enforcement and compliance priorities, which were public safety and jail bonds, sinking fund overfunding, and variable rate bonds.

In regard to public safety bonds, the IRS is determining whether federal government use and management contracts cause excessive private business use that adversely affects the tax-exempt status of public safety bonds.

Last last month the Santa Cruz County Jail District in Arizona filed a public notice that the IRS has made a preliminary determination that its tax-exempt refunding bonds should be treated as retroactively taxable. The March 10 IRS letter said the jail refunding bonds meet the private business use and private payments test because part of the facility is under contract to house federal prisoners.

In regard to sinking fund over-funding, the IRS is focusing on whether over-funding caused the bonds to be arbitrage bonds, which negatively impacts their qualification as Tax Credit Bonds. And for variable-rate bonds, the IRS is determining whether the issuances complied with the rebate and yield restriction rules under IRC Section , the bond and investment yields were properly computed and rebate or yield reduction liability if any was correctly determined.

The IRS audits involving the fair market value of open market securities are determining arbitrage violations under IRC Section , specifically as to the fair market value requirements for yield restricted defeasance escrows under Treasury Regulation 1. The Internal Revenue Service Tax-Exempt Bonds unit closed around fewer examinations in fiscal than had been expected because of the interruption caused by the pandemic.

As a result, the TEB unit closed nearly cases instead of attaining its earlier goal of around cases. The earlier goal had been cited in a presentation to the National Association of Bond Lawyers more than in but was not mentioned when the IRS announced its achievements earlier this year.

Regional News. Log In. Follow Us In Real Time twitter facebook linkedin. Tags IRS Tax audits. By Brian Tumulty April 05, , p. EDT 4 Min Read. Close extra sharing options. As a result, the Tax Exempt Bond unit closed nearly cases instead of attaining its earlier goal of around cases.

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