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Definitions and Special Rules:
This letter is in response to your request on behalf of the Issuer for a ruling that the Issuer will not be treated as a "related party" to either X or Y for purposes of section 1.150-1(d)(2)(ii)(A) of the Income Tax Regulations.
In connection with this request, the City and the Authority represent that the treatment of the Authority Bonds and the City Bonds as separate issues will not result in the avoidance of §103 and 141 through 150 of the Internal Revenue Code.
Whether bonds issued in Year 2 are precluded from being treated as refunding bonds due to the reorganization in Year 1 of the conduit borrower under the prior bonds.
Change in Use of Facilities:
This is in response to a request you submitted on behalf of the Authority for a ruling under §103 of the Internal Revenue Code of 1954 (the "1954 Code") about the effect that a sale of the Plants will have upon interest paid on bonds that financed all or some portion of the Plants.
Whether the sanctions imposed by I.R.C. §150(b)(3) apply where bonds purported to be tax-exempt, but the bond-financed facility was never actually used in a manner qualifying for tax-exempt financing.