The office of Tax Exempt Bonds within the Internal Revenue Service (IRS-TEB) recently released Publication 5091, Voluntary Compliance for Tax-Exempt and Tax-Credit Bonds (Publication 5091). Publication 5091 continues the IRS-TEB emphasis on post issuance compliance and reiterates the need for issuers to establish written compliance procedures. A copy of Publication 5091 can be found here. Part One of this publication includes summaries of certain topics intended to help issuers comply with related federal tax law requirements after issuance of their tax-advantaged bonds (tax-exempt, tax-credit and direct pay). Part Two of this publication includes a summary of the Voluntary Closing Agreement Program that allows issuers to come forward voluntarily to resolve violations which cannot be otherwise remediated under current regulations or guidance. This publication also includes links to other IRS publications that may be useful to issuers and conduit borrowers.
We invite you to contact the Edwards Wildman lawyer responsible for your public finance matters or one of the lawyers listed above if you have any questions regarding Publication 5091, post issuance compliance or the Voluntary Closing Agreement Program.
If you would like further information, please contact the Edwards Wildman lawyer responsible for your matters or one of the authors linked above.