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Federal Taxation of Municipal Bonds Third Edition

Federal Taxation of Municipal Bonds Third Edition

Author: John 0. Swendseid; Neil J. Kaplan; Scott Schickli; Edwin G. Oswald
Publisher: LexisNexis Matthew Bender
ISBN: 9780820572659
Published In: December 2009
Format: Loose-leaf (12 volumes)
Jurisdiction: U.S. ? Disclaimer:
Countri(es) stated herein are used as reference only

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The NABL Library of Publications brings you Federal Taxation of Municipal Bonds.

Federal Taxation of Municipal Bonds remains the library of primary legal sources to have on your bookshelf. The set comes complete with 12 looseleaf volumes, CD-ROM, deskbook, and a web-based version. To ensure that you spend less time looking for the information you need, and more time using it, the Third Edition now includes the FTMB Navigator - a companion guide containing a detailed Table of Contents, Tables of Authorities, Popular Names Table, and a topical Index of all author summaries contained in the multi-volume set.

Prepared and updated throughout the year by a team of experts from the National Association of Bond Lawyers, this publication includes:

l Complete texts of IRC sections relating to municipal bonds, including miscellaneous provisions on marketability, reissuance, original issue discount, market discount, and IRS practice and procedure.

l The full statutory history of every pertinent IRC section, including year of enactment, 1954 Code version (if any), and copies of the complete text of every subsequent amendment.

l Full legislative histories of all pertinent IRC sections, including House, Senate, and Conference Reports, as well as General Explanations (the Blue Book).

l Summaries of related primary law materials organized topically.

l Complete text of all current Treasury regulations applicable to municipal bonds, as well as proposed and withdrawn regulations. Also includes regulations governing state and local government series (SLGS) securities and preambles from current regulations.

l Complete text of pertinent federal case law decisions involving municipal bonds and tax-exempt financing.

l Complete text of all applicable IRS Revenue Rulings, Revenue Procedures, Treasury Notices, General Counsel Memoranda, and Technical Advice Memoranda.

l Complete text of all pertinent IRS Private Letter Rulings and Field Service Advice (more than 2,600 documents).

l Copies of all key IRS and Bureau of Public Debt forms.

Sample Chapter Synopsis

Each chapter provides comprehensive summaries for relevant sections of the Internal Revenue Code.

CHAPTER 1 - SECTION 103 - INTEREST ON STATE & LOCAL BONDS
1.01 INTERNAL REVENUE CODE
[1] Text of Statute - 103 Interest on State and Local Bonds
[2] Statutory History
[3] Effective Dates, Transition Rules and Noncodified Provisions
[4] Cross-References
[5] Prior Law - See 1954 Code in Volume 4
[6] Legislative History

1.02 OTHER INTERNAL REVENUE CODE SECTIONS [Reserved]

1.03 REGULATIONS
1.103-1 Interest Upon Obligations of a State, Territory, Etc.
1.103-2 Dividends from Shares and Stock of Federal Agencies or Instrumentalities.
1.103-3 Interest Upon Notes Secured by Mortgages Executed to Federal Agencies or Instrumentalities.
1.103-4 Interest Upon United States Obligations.
1.103-5 Treasury Bond Exemption in the Case of Trusts or Partnerships.
1.103-6 Interest Upon United States Obligations in the Case of Nonresident Aliens and Foreign Corporations, Not Engaged in Business in the United States.

1.04 SUMMARIES
[1] Qualification as a Political Subdivision
[2] On Behalf of Issuers - 63-20
[3] On Behalf of Issuers - 57-187
[4] On Behalf of Issuers - Other
[5] Nature of Obligation
[6] Nature of Payments as Interest
[7] Ownership of Bonds

VOLUME 1

Chapter 1 Section 103- Interest on State and Local Bonds
Chapter 2 Section 141 - Private Activity Bonds; Qualified Bonds
Chapter 3 Section 142 - Exempt Facility Bonds

VOLUME 2

Chapter 4 Section 143 - Mortgage Revenue Bonds: Qualified Mortgage Bonds and Qualified Veterans' Mortgage Bonds
Chapter 5 Section 144(a) - Qualified Small Issue Bonds
Chapter 6 Section 144(b) - Qualified Student Loan Bonds
Chapter 7 Section 1449(c) - Qualified Redevelopment Bonds
Chapter 8 Section 145 - Qualified 501(c)(3) Bonds
Chapter 9 Section 146 - Volume Cap
Chapter 10 Section 147 - Other Requirements Applicable to Certain Private Activity Bonds

VOLUME 3

Chapter 11 Section 148 - Arbitrage
Chapter 12 Section 149 - Bonds Must be Registered to Be Tax Exempt; Other Requirements
Chapter 13 Section 150 - Definitions and Special Rules
Chapter 14 - Clean Renewable Energy Bonds; Empowerment Zones; Enterprise Communities; Qualified Zone Academy Bonds; Special Rules

VOLUME 4

Chapter 15 - Section 7871 - Indian Tribal Governments Treated as States for Certain Purposes
Chapter 16 - Reissuance
Chapter 17 - Original Issue Discount
Chapter 18 - Section 1275(d) - Contingent Payment Obligations
Chapter 19 - Section 1275(d) - Variable Rate Obligations
Chapter 20 - Original Issue Premium
Chapter 21 - Market Discount
Chapter 22 - Section 1286 - Tax Treatment of Stripped Bonds
Chapter 23 -Provisions Affecting Marketability of Bonds
Chapter 24 - IRS Practice and Procedure

VOLUME 5

1954 Code
Legislative History

VOLUME 6

Legislative History (Continued)
SLGS Regulations
Treasury Forms

VOLUME 7

Cases

VOLUME 8

Treasury Decisions
Revenue Rulings

VOLUME 9

Revenue Procedures

VOLUME 10

Revenue Procedures (Continued)
Revenue Notices
IRS Announcements

VOLUME 11

General Counsel Memoranda

VOLUME 12

Withdrawn Regulations
Proposed Regulations

John O. Swendseid

John 0. Swendseid is a partner in Swendseid and Stern, a Nevada law partnership, which is a member of Denver¿s Sherman & Howard, L.L.C. He received his Bachelor¿s Degree from Gonzaga University in 1974 and his Juris Doctor degree from the University of California, Berkeley (Boalt Hall) in 1977. Mr. Swendseid has practiced municipal finance tax law for over 27. years. He was on the organizing committee of the Bond Attorney¿s Workshop for three years and was the Chair of NABL¿s Tax and Securities Law Institute in 2004. Mr. Swendseid is admitted to practice law in/Colorado and Nevada.

Neil J. Kaplan

Neil J. Kaplan is a partner in the firm of Sidley Austin Brown & Wood. He has practiced tax law in the public finance area for more than 15 years. Mr. Kaplan has had the responsibility for tax work on many areas of tax-exempt financing, including Section 501(c)(3) organizations, advance refundings, general obligations, airports, hospital pool transactions and small issue IDBs.

Scott Schickli

Scott Schickli, Of Counsel in Orrick¿s Pacific Northwest office, is a member of the Tax Department in Portland, Oregon. Scott¿s practice focuses on federal income tax law of public finance, low income housing, and exempt organizations. Scott received an LL.M. from the New York University Law School in 198 7, a J.D. from the University of Minnesota Law School in 1981 and a B.A. from the Carleton College in 1973. Scott is an active member of the state bars of Oregon, New York and Alaska.

Edwin G. Oswald

Edwin G. Oswald is a partner in the firm of Orrick, Herrington & Sutcliffe LLP, specializing in taxation of municipal finance transactions. He received his B.S. and J.D. from St. John's University in New York. Mr. Oswald was an attorney in the U.S. Department of Treasury's Office of Tax Policy where he developed policy, legislative initiatives and regulations affecting public finance and structured finance. He is a member of the bars of New York, the District of Columbia and the State of Connecticut.