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Section 103 - Interest on State and Local Bonds, Political Subdivision

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Interest on State and Local Bonds:

CCAAM2012-003
This Chief Counsel Advice responds to a request for assistance regarding dissolution of certain redevelopment agencies.

PLR 201110007 (3/11/11)
This letter is in response to a request for a ruling that the demolition of the Project Facilities (1) will not cause the interest on the Bonds to fail to be excludable from gross income under section 103 of the Internal Revenue Code of 1954 ("the 1954 Code") and (2) will not cause section 150(b) of the Internal Revenue Code of 1986 ("the 1986 Code") to apply, precluding Borrower from deducting interest on the financing agreements relating to the Bonds.

PLR 201104020 (1/28/11)
This responds to a request for a ruling either that (1) Authority qualifies as a political subdivision for purposes of § 103 of the Internal Revenue Code (the “Code”), or (2) the debt of Authority is issued on behalf of City within the meaning of § 1.103-1(b) of the Income Tax Regulations.

PLR200746017 (Tax Exempt Interest under Section 103 of the Internal Revenue Code)
Whether a nonprofit corporation is a political subdivision under the meaning of Treas. Reg. section 1.103-1(b). If the nonprofit corporation is not a political subdivision, whether its debt is issued on behalf of a State or local governmental unit within the meaning Treas. Reg. section 1.103-1(b).

PLR200413010 (12/11/2003)
This letter is in response to your request on behalf of the State for a ruling that the Registered Warrants will be "obligations" of the State for purposes of section 103 of the Code.

PLR200336004 (09/05/2003)
This is in response to your request on behalf of the State for a ruling that the Warrants will be "obligations of the State" for purposes of section 103 of the Code.

PLR200324024 (12/31/2002)
This letter is in response to your request for a ruling on behalf of the Authority that the authority is an instrumentality of one or more political subdivisions of the State for purposes of sections 103 and 141 of the Code.

PLR200204032
This letter is in response to a request for a ruling that the Agency qualifies as a political subdivision of the State for purposes of §103 of the Internal Revenue Code and that, accordingly, the Agency is not required to file federal income tax returns or pay federal income tax on its income.

FSA200116012
Whether the information provided supports a determination that the transaction enabled the parties to exploit the difference between tax-exempt and taxable rates.

PLR200035025
This letter is in response to a request for a ruling, on behalf of the Issuer, that a proposed new bond issue (the "New Bonds") will be treated as a current refunding issue, refunding the Y Bonds, within the meaning of §1.150-1(d) of the Income Tax Regulations and §1313(a) of the Tax Reform Act of 1986, as amended (the "Act").

FSA200035020
Whether the information provided supports a determination that the transaction enabled the parties to exploit the difference between tax-exempt and taxable rates.

FSA199925011
Whether there are sufficient facts to support an argument that Bonds 2 were a reissuance of Bonds 1?

PLR200022028
This is in response to a request for rulings on behalf of the Corporation that (1) any income derived by the Corporation as a result of its proposed activities, as further described below, will be excludable from gross income under §115 of the Internal Revenue Code, (2) the Bonds to be issued by the Corporation will be considered as issued on behalf of the State under §103, and (3) the Corporation is an instrumentality of the State under §141.

PLR200017018
This letter is in response for a request for a ruling that the Authority qualifies as a political subdivision of the State for purposes of §103 of the Internal Revenue Code.

FSA200002014
Whether tax-exempt bond proceeds deposited in a fund established at the requirement of a third party lender are spent, thereby precluding the issuer from using such proceeds to satisfy the requirement that 95 percent of the net proceeds be expended for qualified redevelopment activities.

PLR199926013
This letter is in response for a request for a ruling regarding the purchase of gas properties.

FSA199926004
Whether a city and redevelopment agency's agreement to reimburse a partnership for the costs of developing real property constitutes an obligation within the meaning of I.R.C. 103, causing interest payments received under the agreement to be tax-exempt.

 


Political Subdivision:

PLR 201114010 (4/8/11)
This responds to a request for rulings that (1) Authority qualifies as a political subdivision for purposes of § 103 of the Internal Revenue Code (the “Code”), and (2) authority is not a “related party” to either City or District under § 1.150-1(b) of the Income Tax Regulations.

PLR 201110007 (3/11/11)
This letter is in response to a request for a ruling that the demolition of the Project Facilities (1) will not cause the interest on the Bonds to fail to be excludable from gross income under section 103 of the Internal Revenue Code of 1954 ("the 1954 Code") and (2) will not cause section 150(b) of the Internal Revenue Code of 1986 ("the 1986 Code") to apply, precluding Borrower from deducting interest on the financing agreements relating to the Bonds.

PLR200406003 (02/06/2004)
This letter responds to Issuer's request for a ruling that the Corporation meets the criteria of Revenue Ruling 57-128 and therefore is an instrumentality of a political subdivision for purposes of section 141 of the Internal Revenue Code.

PLR200238001 (04/15/2002)
This letter is in response to your request for a ruling that the District is a political subdivision of the State, that the District's incomes is excluded from gross income, and that the salaries and wages of the District's employees are exempt from federal income tax.

PLR200227023 (04/02/2002)
This correspondence is in reply to the letter dated November 7, 2001, from your authorized representative, requesting a ruling that Authority is a political subdivision, as defined in Section 1.103-1(b), and that its income is not subject to federal income tax.

 

Page Last Reviewed or Updated: 07-Apr-2014