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House Stimulus Bill Expands Tax Credit Bonds; IRS Reformulates Pricing House Stimulus Bill Expands Tax Credit Bonds; IRS Reformulates Pricing

House Stimulus Bill Expands Tax Credit Bonds; IRS Reformulates Pricing - PDF document

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Uploaded On 2015-10-07

House Stimulus Bill Expands Tax Credit Bonds; IRS Reformulates Pricing - PPT Presentation

On Friday January 16 2009 HR and Reinvestment Tax Act of 2009148 147ARRTA148 was introduced by Rep of a substitute that affects AARTA was presented The materials below and Qualix006 ID: 152866

Friday January 2009

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House Stimulus Bill Expands Tax Credit Bonds; IRS Reformulates Pricing for Tax Credit Rate on On Friday, January 16, 2009, HR and Reinvestment Tax Act of 2009” (“ARRTA”), was introduced by Rep. of a substitute that affects AARTA was presented. The materials below and Quali�ed Zone Academy Bonds Sections 1611 and 1612 of ARRTA respectively. Each of the New CREBs Improvement and Extension Act of green community programs. The report from the Joint Committee on Taxation, the change “ . . . will enable States to issue ARRTA proposes to increase the 2009 of $1.4 billion. The October 2008 bailout “Tax Extenders and Alternative Minimum Relief Act of 2008” that reauthorized and extended the existing QZAB program. As a result, $400 million in allocation was added Habitat, Harvest and Horticulture Act of 2008.” Section 54A makes signi�cant (Section 1397E). Those changes include, William H. McBrid Client Alert Tax Credit Bonds for Quali�ed School Section 1511 of ARRTA proposes to Section 54A. This category of tax credit of such issue.” The allocation for QSCB is $11 billion for each of calendar years 2009 and 2010. There is an additional Native American schools. Of the total Unused allocation may be carried over, and ARRTA does not place a limit on the years to which it may be carried over. Credit Option for Taxable Section 1521 of ARRTA proposes to of taxable governmental bonds. The 54AA of the Code and would be entitled “Taxable Bond Option for Governmental takes into account the amount of interest payable on the bond. The amount of ment of interest under such bond.” The under Section 54A. The interest on the lieu of the holder receiving a credit. To qualify, 100% of the available project this option. The Treasury would pay date. This provision would apply to bonds issued before January 1, 2011. and Tribal Economic Development There are other provisions of ARRTA Moreover, pooled bonds may be bank the amount of qualifying tax-exempt debt In other words, in calculating the existing as if the 501(c)(3) entity is the issuer.Lastly, Section 1503 of ARRTA provides that private activity bonds issued in 2009 and 2010 would not be subject to AMT. $10 billion and $15 billion, respectively, in allocation. The allocation would be must be issued before January 1, 2011. A recovery zone is either an area, designated by the issuer, with signi�cant poverty, unemployment or rate of home munity is in effect. A recovery zone also A recovery zone economic development of 35%. The bond requires 100% of A recovery zone facility bond shall 142 of the Code. At least 95% of the used for recovery zone property. To be recovery zone property, it generally zone designation took effect, is �rst used in the zone by the taxpayer, is in such zone. A quali�ed business is in Section 147(d) shall not apply. A new category of tribal economic allocation of $2 billion. A bond quali�es Treasury is required to conduct a study Changes to Tax Credit Rateseffective as of January 22, 2009, the Treasury will determine and announce selected by the Treasury Department in grade rating of between A and BBB . The rates will be published on the website for https://www.treasurydirect.https://www.rate on outstanding AA rated corporate bonds. This change is subject to further re�nement and modi�es Notice 2007-26, Atlanta • Austin • Bangkok • Beijing • Brussels • Charlotte • Dallas • Houston • London • Los Angeles • McLean • Miami • New York • Norfolk • Raleigh • Richmond • San Francisco • Singapore • Washington © 2009 Hunton & Williams LLP. Attorney advertising materials. These materials have been prepared for informational purposes only and are not legal advice. This information is not intended to create an attorney-client or similar relationship. Please do not send us con�dential information. Past successes cannot be an assurance of future success. Whether you need legal services and which lawyer you select are important decisions that should not be based solely upon these materials. Contact: Walfrido J. Martinez*, Hunton & Williams LLP, 200 Park Avenue, New York, NY 10166, (212) 309-1000. *Licensed to practice in Florida and New Jersey only.