The freely available Adobe Acrobat Reader software is required to view, print, and search the rulings and memoranda listed below. Interest on state and local bonds: AM2012-004 PDF This Chief Counsel Advice responds to a request for assistance regarding dissolution of certain redevelopment agencies. PLR 201110007 (3/11/11) PDF This letter is in response to a request for a ruling that the demolition of the Project Facilities (1) will not cause the interest on the Bonds to fail to be excludable from gross income under section 103 of the Internal Revenue Code of 1954 ("the 1954 Code") and (2) will not cause section 150(b) of the Internal Revenue Code of 1986 ("the 1986 Code") to apply, precluding Borrower from deducting interest on the financing agreements relating to the Bonds. PLR 201104020 (1/28/11) PDF This responds to a request for a ruling either that (1) Authority qualifies as a political subdivision for purposes of § 103 of the Internal Revenue Code (the “Code”), or (2) the debt of Authority is issued on behalf of City within the meaning of § 1.103-1(b) of the Income Tax Regulations. PLR200646017 (Tax Exempt Interest under Section 103 of the Internal Revenue Code) PDF Whether a nonprofit corporation is a political subdivision under the meaning of Treas. Reg. section 1.103-1(b). If the nonprofit corporation is not a political subdivision, whether its debt is issued on behalf of a State or local governmental unit within the meaning Treas. Reg. section 1.103-1(b). PLR200413010 (12/11/2003) PDF This letter is in response to your request on behalf of the State for a ruling that the Registered Warrants will be "obligations" of the State for purposes of section 103 of the Code. PLR200336004 (09/05/2003) PDF This is in response to your request on behalf of the State for a ruling that the Warrants will be "obligations of the State" for purposes of section 103 of the Code. PLR 200314024 (12/31/2002) PDF This letter is in response to your request for a ruling on behalf of the Authority that the authority is an instrumentality of one or more political subdivisions of the State for purposes of sections 103 and 141 of the Code. PLR200204032 PDF This letter is in response to a request for a ruling that the Agency qualifies as a political subdivision of the State for purposes of §103 of the Internal Revenue Code and that, accordingly, the Agency is not required to file federal income tax returns or pay federal income tax on its income. FSA200116012 PDF Whether the information provided supports a determination that the transaction enabled the parties to exploit the difference between tax-exempt and taxable rates. PLR200035025 PDF This letter is in response to a request for a ruling, on behalf of the Issuer, that a proposed new bond issue (the "New Bonds") will be treated as a current refunding issue, refunding the Y Bonds, within the meaning of §1.150-1(d) of the Income Tax Regulations and §1313(a) of the Tax Reform Act of 1986, as amended (the "Act"). FSA200035020 PDF Whether the information provided supports a determination that the transaction enabled the parties to exploit the difference between tax-exempt and taxable rates. FSA199925011 PDF Whether there are sufficient facts to support an argument that Bonds 2 were a reissuance of Bonds 1? PLR200022028 PDF This is in response to a request for rulings on behalf of the Corporation that (1) any income derived by the Corporation as a result of its proposed activities, as further described below, will be excludable from gross income under §115 of the Internal Revenue Code, (2) the Bonds to be issued by the Corporation will be considered as issued on behalf of the State under §103, and (3) the Corporation is an instrumentality of the State under §141. PLR200017018 PDF This letter is in response for a request for a ruling that the Authority qualifies as a political subdivision of the State for purposes of §103 of the Internal Revenue Code. FSA200002014 PDF Whether tax-exempt bond proceeds deposited in a fund established at the requirement of a third party lender are spent, thereby precluding the issuer from using such proceeds to satisfy the requirement that 95 percent of the net proceeds be expended for qualified redevelopment activities. FSA199926004 PDF Whether a city and redevelopment agency's agreement to reimburse a partnership for the costs of developing real property constitutes an obligation within the meaning of I.R.C. 103, causing interest payments received under the agreement to be tax-exempt. Political subdivision: PLR 201114010 (4/8/11) PDF This responds to a request for rulings that (1) Authority qualifies as a political subdivision for purposes of § 103 of the Internal Revenue Code (the “Code”), and (2) authority is not a “related party” to either City or District under § 1.150-1(b) of the Income Tax Regulations. PLR 201110007 (3/11/11) PDF This letter is in response to a request for a ruling that the demolition of the Project Facilities (1) will not cause the interest on the Bonds to fail to be excludable from gross income under section 103 of the Internal Revenue Code of 1954 ("the 1954 Code") and (2) will not cause section 150(b) of the Internal Revenue Code of 1986 ("the 1986 Code") to apply, precluding Borrower from deducting interest on the financing agreements relating to the Bonds. PLR200406003 (02/06/2004) PDF This letter responds to Issuer's request for a ruling that the Corporation meets the criteria of Revenue Ruling 57-128 and therefore is an instrumentality of a political subdivision for purposes of section 141 of the Internal Revenue Code. PLR200238001 (04/15/2002) PDF This letter is in response to your request for a ruling that the District is a political subdivision of the State, that the District's incomes is excluded from gross income, and that the salaries and wages of the District's employees are exempt from federal income tax. PLR200227023 (04/02/2002) PDF This correspondence is in reply to the letter dated November 7, 2001, from your authorized representative, requesting a ruling that Authority is a political subdivision, as defined in Section 1.103-1(b), and that its income is not subject to federal income tax.
