Orrick Tax Talk 10 - Change in Use/VCAP

In certain circumstances, an issuer or borrower of tax-exempt bonds may seek to change the use of bond financed property during the life of that property, which could include selling the property. This would constitute a “deliberate act” to move a bond finance property from compliant to non-compliant in relation to certain IRS rules. Certain “deliberate acts” are permitted, however, as long as the issuer or borrower takes advantage of certain self-help rules to help them fix the corresponding tax problem. Listen to this video to learn about self-help rules and the Voluntary Closing Agreement Program as related to change in use of tax-exempt bond financed property.

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Other Tax Talk Videos
1. The ABC’s of Governmental Bonds
2. The ABC’s of 501(c)(3) Bonds
3. Private Business Use
4. Private Payments
5. Management Contracts (video removed – see video #13)
6. Sponsored Research Contracts
7. Private Activity Bonds
8. Tax Credit Bonds (video removed as tax credit bonds can no longer be issued)
9. Post-Issuance Tax Compliance
10. Change in Use/VCAP
11. IRS Audits
12. Allocation of Bond Proceeds and Floating Equity
13. Management Contracts – New 2017 Rules

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