TEB administers the Voluntary Closing Agreement Program (TEB VCAP) to assist governmental issuers in resolving violations of the federal tax laws applicable to their tax-exempt, tax credit, or direct pay bonds (tax-advantaged bonds). Under TEB VCAP, issuers can conclusively resolve violations through the execution of closing agreements with the Service.
The primary compliance objective of the TEB VCAP resolution standards is to promote due diligence on the part of issuers and other parties to bond transactions in resolving violations of applicable federal tax laws. In furtherance of this objective, the resolution standards provide an economic incentive for issuers to timely identify violations and submit TEB VCAP requests. The primary administrative objective of these resolution standards is to streamline the closing agreement process with respect to specific violations resulting in more efficient processing of cases.
IRM 7.2.3: 7. Rulings and Agreements, Chapter 2. TE/GE Closing Agreements, Section 3. Tax Exempt Bonds Voluntary Closing Agreement Program provides procedures for TEB VCAP. Links to the various sections of this IRM relating to TEB VCAP resolution standards are organized below.
Objectives & Scope
These IRM procedures provide general information about the objectives and scope of the TEB VCAP resolution standards.
Resolution Standards for Tax Exempt Bonds
These IRM procedures describe the resolution standards for 9 specific violations of federal tax laws applicable to tax-exempt bonds.
Resolution Standards for Direct Pay Bonds
These IRM procedures describe the resolution standards for 4 specific violations of federal tax laws applicable to certain direct pay bonds.
Implementation of Standards
These IRM procedures describe the implementation of TEB VCAP resolution standards. This includes modifications to the calculation of the closing agreement payment based on the amount of time between the deliberate action giving rise to the compliance failure and the submission of the VCAP request.