For the past several years, the Internal Revenue Service (“IRS”) has increased its attention on tax-exempt bond post-issuance compliance. Through the introduction of Form 990, Schedule K (Supplemental Information on Tax-Exempt Bonds), revisions to its Voluntary Closing Agreement Program (“VCAP”) to promote the implementation of written post-issuance compliance procedures, the use of compliance check questionnaires to evaluate compliance trends and practices and additional hiring to facilitate more tax-exempt bond audit activity, the IRS is making it very clear that now, more than ever, issuers and borrowers of tax-exempt bonds need to focus on post-issuance compliance.
In the alternative, on June 7th, the IRS will present a free telephone forum discussing the tax-exempt bond examination process. Registration for the forum is available here.
If you have questions following the telephone forum or are unable to listen, please feel free to contact your regular Hall Render attorney and/or keep an eye out for our summary, which will be published shortly after the forum’s conclusion.
