Private-Letter Ruling Sheds Light on Parity Funds

Barnett, Susanna Duff
October 2004
Bond Buyer;10/12/2004, Vol. 350 Issue 31987, p4
Trade Publication
Reports on a U.S. Internal Revenue Service (IRS) private-letter ruling which determined that bond proceeds from a parity reserve fund can be used to redeem some of the issues backed by the fund without causing the bond issues that generated those bond proceeds to be considered refunded. Views of issuers and counsel facing similar circumstances about the ruling; IRS ruling's reference to a provision of the Treasury regulations that says the determination of whether an issue is a refunding issue is based on the substance of the transaction in light of all the facts and circumstances.


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