[Federal Register Volume 80, Number 121 (Wednesday, June 24, 2015)]
[Proposed Rules]
[Pages 36301-36305]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-15411]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-138526-14]
RIN 1545-BM46
Issue Price Definition for Tax-Exempt Bonds
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Partial withdrawal of notice of proposed rulemaking, notice of
proposed rulemaking, and notice of public hearing.
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SUMMARY: This document partially withdraws the portion of the notice of
proposed rulemaking published in the Federal Register on September 16,
2013 (78 FR 56842), relating to the definition of issue price for
purposes of the arbitrage restrictions under section 148 of the
Internal Revenue Code (Code). This document also contains a notice of
proposed rulemaking that provides a revised definition of issue price
for purposes of the arbitrage restrictions. In addition, this document
provides notice of a public hearing on the proposed regulations in this
document. The proposed regulations in this document affect issuers of
tax-exempt and other tax-advantaged bonds.
DATES: Written or electronic comments must be received by September 22,
2015. Requests to speak and outlines of topics to be discussed at the
public hearing scheduled for October 28, 2015, at 10:00 a.m., must be
received by September 22, 2015.
ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-138526-14), Internal
Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC
20044. Submissions may be hand delivered to: CC:PA:LPD:PR Monday
through Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR
(REG-138526-14), Courier's Desk, Internal Revenue Service, 1111
Constitution Avenue NW, Washington, DC, or sent electronically via the
Federal eRulemaking Portal at www.regulations.gov (IRS REG-138526-14).
The public hearing will be held at the Internal Revenue Building, 1111
Constitution Avenue NW., Washington, DC.
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations,
Lewis Bell at (202) 317-6980; concerning submissions of comments and
the hearing, Oluwafunmilayo (Funmi) Taylor at (202) 317-6901 (not toll-
free numbers).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information contained in Sec. 1.148-1 has been
reviewed and approved by the Office of Management and Budget in
accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d))
under control number 1545-1347. The collection of information in this
proposed regulation is in Sec. 1.148-1(f)(2)(ii) which contains a
requirement that the issuer obtain certifications and supporting
documentation regarding the underwriter's sales of the issuer's bonds.
The collection of information in Sec. 1.148-1(f)(2)(ii) is an increase
in the total annual burden under control number 1545-1347. The
respondents are issuers of tax-exempt bonds that wish to use the
alternative method in Sec. 1.148-1(f)(2)(ii).
Estimated total annual recordkeeping burden: 52,276 hours.
Estimated average annual burden hours per respondent: 4 hours.
Estimated number of respondents: 12,546.
Estimated annual frequency of responses: 20,910.
Comments on the collection of information should be sent to the
Office of Management and Budget, Attn: Desk Officer for the Department
of the Treasury, Office of Information and Regulatory Affairs,
Washington, DC 20503, with copies to the Internal Revenue Service,
Attn: IRS Reports Clearance Officer, SE:CAR:MP:T:T:SP, Washington DC
20224. Comments on the collection of information should be received by
August 24, 2015.
Comments are sought on whether the proposed collection of
information is necessary for the proper performance of the IRS,
including whether the information will have practical utility;
The accuracy of the estimated burden associated with the proposed
collection of information;
How the quality, utility, and clarity of the information to be
collected may be enhanced;
How the burden of complying with the proposed collection of
information may be minimized, including through the application of
automated collection techniques and other forms of information
technology; and
Estimates of capital or start-up costs and costs of operation,
maintenance,
[[Page 36302]]
and purchase of service to provide information.
An agency may not conduct or sponsor, and a person is not required
to respond to, a collection of information unless it displays a valid
control number assigned by the Office of Management and Budget.
Books or records relating to a collection of information must be
retained as long as their contents may become material in the
administration of any internal revenue law. Generally tax returns and
tax return information are confidential, as required by section 6103.
Background
This document contains proposed amendments to the Income Tax
Regulations (26 CFR part 1) on the arbitrage investment restrictions
under section 148 of the Code. On June 18, 1993, the Department of the
Treasury (Treasury Department) and the IRS published comprehensive
final regulations in the Federal Register (TD 8476, 58 FR 33510) on the
arbitrage investment restrictions and related provisions for tax-exempt
bonds under sections 103, 148, 149, and 150. Since that time, those
final regulations have been amended in certain limited respects (the
regulations issued in 1993 and the amendments thereto are collectively
referred to as the Existing Regulations).
A notice of proposed rulemaking was published in the Federal
Register (78 FR 56842; REG-148659-07) on September 16, 2013 (the 2013
Proposed Regulations), which proposes amendments to the Existing
Regulations to address market developments, simplify certain
provisions, address certain technical issues, and make the regulations
more administrable. One significant change in the 2013 Proposed
Regulations addresses the definition of issue price. Comments were
received, and a public hearing was held on February 5, 2014. After
considering the comments and the statements made at the public hearing,
the Treasury Department and the IRS have decided to withdraw Sec.
1.148-1(f) of the 2013 Proposed Regulations relating to issue price and
to propose new regulations. This document (the Proposed Regulations)
contains the re-proposed definition of issue price. The Treasury
Department and the IRS will address the remaining provisions contained
in the 2013 Proposed Regulations at a later time.
Explanation of Provisions
For purposes of the arbitrage investment restrictions, section
148(h) provides that yield on an issue is to be determined on the basis
of the issue price (within the meaning of sections 1273 and 1274). The
reason for using issue price (rather than sales proceeds less the costs
of issuance) to determine yield for purposes of section 148(h) is to
ensure that issuers bear the costs of issuance, rather than recover
these costs through arbitrage profits. See H. Rep. No. 99-426, at 517
(1985). Congress thought that this requirement would encourage issuers
to scrutinize costs of issuance more closely and would encourage better
targeting of the federal subsidy associated with tax-exempt bonds. Id.,
at 517-518. The issue price definition under the Existing Regulations
generally follows the issue price definition used for computing
original issue discount on debt instruments under sections 1273 and
1274, with certain modifications. The definition under the Existing
Regulations provides that generally the issue price of bonds that are
publicly offered is the first price at which a substantial amount of
the bonds is sold to the public. However, the issue price definition in
the Existing Regulations defines substantial amount as ten percent and
applies a reasonable expectations standard (rather than a standard
based on actual sales) for determining the issue price of bonds that
are publicly offered. Specifically, the issue price of bonds for which
a bona fide public offering is made is determined as of the sale date
based on reasonable expectations regarding the initial offering price.
The issue prices of bonds with different payment and credit terms are
determined separately. Notice 2010-35, published May 10, 2010 (2010-19
IRB 660), provides that the arbitrage definition of issue price also
applies to other tax-advantaged bond programs, including Build America
Bonds under section 54AA and other Qualified Tax Credit Bonds under
section 54A.
The definition of issue price in the 2013 Proposed Regulations
differs significantly from that in the Existing Regulations. Consistent
with section 148(h), the 2013 Proposed Regulations retain the rule that
issue price generally will be determined under the rules of sections
1273 and 1274. The 2013 Proposed Regulations parallel the language in
the existing section 1273 regulations by providing that the issue price
of tax-exempt bonds issued for money is the first price at which a
substantial amount of the bonds is sold to the public. The 2013
Proposed Regulations provide a safe harbor under which an issuer may
treat the first price at which a minimum of 25 percent of the bonds in
an issue (with the same credit and payment terms) actually is sold to
the public as the issue price, provided that all orders at this price
received from the public during the offering period are filled (to the
extent that the public orders at such price do not exceed the amount of
bonds sold). Thus, the 2013 Proposed Regulations base the determination
of issue price on actual sales prices instead of reasonably expected
sales at initial public offering prices. The 2013 Proposed Regulations
also remove the definition of a ``substantial amount'' as ten percent.
The 2013 Proposed Regulations define the term ``public'' to mean
any person other than an ``underwriter.'' The 2013 Proposed Regulations
define the term ``underwriter'' to mean any person that purchases bonds
from the issuer for the purpose of effecting the original distribution
of the bonds or otherwise participates directly or indirectly in the
original distribution. An underwriter includes a lead underwriter and
any member of a syndicate that contractually agrees to participate in
the underwriting of the bonds for the issuer. A securities dealer
(whether or not a member of the issuer's underwriting syndicate) that
purchases bonds (whether or not from the issuer) for the purpose of
effecting the original distribution of the bonds is also treated as an
underwriter for this purpose. An underwriter generally includes a party
related to an underwriter. A person that holds bonds for investment is
not an underwriter with respect to those bonds.
A number of comments were received on the 2013 Proposed Regulations
issue price definition. In general, the commenters requested the
withdrawal of the portion of the 2013 Proposed Regulations relating to
the definition or the re-proposal of the definition using the existing
reasonable expectations test regarding the initial public offering
price, with certain clarifications. Commenters pointed out that issue
price must be determined as of the sale date to provide certainty that
the bonds will qualify as tax-exempt and meet state or local
requirements for debt issuance. The sale date is the date when the
syndicate or sole underwriter in contractual privity with the issuer
signs the agreement to buy the bonds from the issuer and when the terms
of the bond issue are set. Commenters expressed concern about
insufficient sales of bonds preventing a timely determination of issue
price on the sale date. The commenters noted that the syndicate or sole
underwriter in contractual privity purchases the bonds from the issuer,
so the syndicate or sole
[[Page 36303]]
underwriter, rather than the issuer, will bear the risk of any market
fluctuations after the sale date. Because the issuer neither bears this
risk nor receives any further proceeds, any later change in price is
not a factor that affects the costs of issuance paid by the issuer. In
addition, later sales prices could reflect changes in the market,
whereas the purpose of using issue price is to preclude recovery of
issuance costs through arbitrage profits. See H. Rep. No. 99-426, at
517.
In general, the lower the issue price for the bonds bearing a
stated interest rate, the higher the yield. Economically, the issuer
should want to receive the highest price for the bonds and pay the
lowest yield. This aligns with the purpose of the arbitrage provisions
to minimize arbitrage investment benefits and remove incentives to
issue more tax-exempt bonds, and thus to limit the federal revenue cost
of the tax subsidy for tax-exempt bonds. Many of the commenters stated,
however, that the use of actual sales prices likely would result in
lower bond offering prices so as to ensure that each issue would meet
the 25 percent threshold in the safe harbor in the 2013 Proposed
Regulations as of the sale date of the bonds. The commenters pointed to
unsold bonds in particular maturities of an overall tax-exempt bond
issue that includes a series of bonds with separate maturities and
issue prices as the particular impediment to meeting an actual sale
requirement as of the sale date. These lower bond prices would reduce
proceeds and increase borrowing costs for issuers, increase bond yields
for arbitrage purposes, and increase federal tax subsidies.
In addition, commenters suggested that the definition of
underwriter in the 2013 Proposed Regulations was unduly broad and
ambiguous. In particular, commenters expressed concern that the 2013
Proposed Regulations effectively required the issuer to obtain price
information from dealers that are not in a contractual relationship
with the issuer or underwriting syndicate. The commenters also
expressed concern that the proposed definition of underwriter
necessitated determining a dealer's intent for buying bonds because
whether a dealer was an underwriter depended upon whether the dealer
purchased bonds with ``the purpose of effecting the original
distribution of the bonds.''
In response to the comments received, the Treasury Department and
the IRS are re-proposing an amended definition of issue price for tax-
exempt bonds. Consistent with section 148(h), the Proposed Regulations
retain the rule that issue price generally will be determined under the
rules of sections 1273 and 1274. The Proposed Regulations also parallel
the language in the existing section 1273 regulations and the Existing
Regulations by providing that the issue price of bonds issued for money
is the first price at which a substantial amount of the bonds is sold
to the public. This rule uses actual sales to determine issue price and
is consistent with section 1273. The Proposed Regulations retain the
rule in the Existing Regulations that ten percent is a substantial
amount.
The Proposed Regulations also retain the rule for tax-exempt bonds
that the issue prices of bonds with different payment and credit terms
are determined separately. Tax-exempt bond issues often include bonds
with different payment and credit terms that generally sell at
different prices. In response to commenters' concerns regarding the
need for certainty with respect to the determination of issue price of
the issue as of the sale date and that less than a substantial amount
of particular bonds included within an issue may be sold by that time,
the Proposed Regulations provide an alternative method of determining
issue price for bonds a substantial amount of which is not sold
pursuant to orders received from the public as of the sale date. Under
this alternative method, an issuer may treat the initial offering price
to the public as the issue price, provided certain requirements are
met.
In particular, the alternative method requires that the
underwriters fill all orders at the initial offering price placed by
the public and received by the underwriters on or before the sale date
(to the extent the orders do not exceed the amount of bonds to be sold)
and do not fill any order received by the underwriters on or before the
sale date at a price higher than the initial offering price. Further,
the alternative method requires the lead underwriter (or sole
underwriter, if applicable) to provide certification with respect to
certain matters under the alternative method, including a certification
that no underwriter will fill an order received from the public after
the sale date and before the issue date at a price higher than the
initial offering price, except if the higher price is the result of a
market change for those bonds after the sale date (for example, due to
a change in interest rates), and that it will provide the issuer with
supporting documentation for the matters covered by the certifications.
Documentation of the initial offering price may include a copy of
the pricing wire (or equivalent communication). Documentation of bonds
for which an underwriter filled an order placed by the public after the
sale date and before the issue date at a price higher than the initial
offering price includes both pricing information (amounts, prices, and
sale dates) and information regarding the corresponding market change,
such as proof of the values of a broad-based index of municipal bond
interest rates on bonds similar to the type and credit rating of the
bonds being sold. The issuer must not know or have reason to know,
after exercising due diligence, that the certifications are false.
The Treasury Department and the IRS recognize that, under syndicate
agreements among underwriters and MSRB rules, underwriters are free to
sell bonds after the bond purchase agreement is signed at a fair and
reasonable price different from the initial offering price. The
alternative method allows the use of initial offering price as the
issue price in circumstances in which bonds are sold after the sale
date and before the issue date at a higher price, provided that the
higher price results from a market change for those bonds after the
sale date. Based on available data, the Treasury Department and the IRS
believe that the frequency of sales by underwriters at higher prices
between the sale date and the issue date is limited. Thus, the burden,
in effect, of requiring underwriters to maintain initial public
offering prices for unsold bonds until the issue date absent
justification for higher prices based on market changes should be
limited. The Treasury Department and the IRS request comments on other
safeguards or alternative approaches to ensure that the prices obtained
by underwriters in actual sales of bonds to the public between the sale
date and the issue date are consistent with use of initial offering
prices to the public as of the sale date as a simplifying assumption
for issue price determinations in the alternative method.
The Proposed Regulations define ``public'' for purposes of
determining the issue price of tax-exempt bonds as any person other
than an underwriter or a related party to an underwriter. The Proposed
Regulations define ``underwriter'' to include (i) any person that
contractually agrees to participate in the initial sale of the bonds to
the public by entering into a contract with the issuer or into a
contract with a lead underwriter to form an underwriting syndicate and
(ii) any person that, on or before the sale date, directly or
indirectly enters into a contract or other arrangement to sell the
bonds with any of the foregoing (for example, a retail
[[Page 36304]]
distribution contract between a member of an underwriting syndicate or
selling group and another dealer that is not in the syndicate or
selling group).
The Proposed Regulations remove as unnecessary a rule in the
Existing Regulations expressly stating that the issue price does not
change if part of the issue is later sold at a different price. The
Treasury Department and the IRS intend no substantive change by the
removal.
In accordance with section 6001, the issuer should maintain
documentation in its books and records to support its issue price
determinations. This documentation includes the specific certifications
and documentation required to determine issue price under the
alternative method, as well as documentation to support issue price
determinations under the general rule. For example, under the general
rule, an issuer should include in its books and records any
certification from the lead (or sole) underwriter regarding the first
price at which a substantial amount of the bonds were sold to the
public and reasonable supporting documentation for this price.
Proposed Effective/Applicability Date
The Proposed Regulations are proposed to apply prospectively to
bonds that are sold on or after the date that is 90 days after
publication of the Treasury decision adopting these rules as final
regulations in the Federal Register. In addition, issuers may rely upon
the Proposed Regulations with respect to bonds that are sold on or
after June 24, 2015, and before the date that is 90 days after
publication of the Treasury decision adopting these rules as final
regulations in the Federal Register.
Special Analyses
It has been determined that this notice of proposed rulemaking is
not a significant regulatory action as defined in Executive Order
12866, as supplemented by Executive Order 13563. Therefore, a
regulatory assessment is not required. It has also been determined that
section 553(b) of the Administrative Procedure Act (5 U.S.C. Chapter 5)
does not apply.
It is hereby certified that these Proposed Regulations, if adopted,
would not have a significant economic impact on a substantial number of
small entities. Therefore, a Regulatory Flexibility Analysis under the
Regulatory Flexibility Act (5 U.S.C. chapter 6) is not required. This
certification is based generally on the fact that any effect on small
entities by these rules generally flows from section 148 of the Code.
Section 148(h) of the Code requires the yield on an issue of bonds
to be determined on the basis of issue price (within the meaning of
sections 1273 and 1274). Under section 1273, the issue price is the
first price at which a substantial amount of the bonds were sold to the
public. Section 1.148-1(f)(2)(ii) of the Proposed Regulations gives
effect to the statute by requiring the issuer to obtain certifications
and documentation regarding sales of the bonds from the underwriter of
the bonds, which is the party that sells the bonds to the public. This
information will be used to support the issue price of the bonds for
audit and other purposes. Any economic impact of obtaining this
information is minimal because most of the information already is
provided to issuers by the underwriters under existing industry
practices. Accordingly, these proposed changes do not add to the impact
on small entities imposed by the statutory provision. Pursuant to
section 7805(f) of the Code, this notice of proposed rulemaking has
been submitted to the Chief Counsel for Advocacy of the Small Business
Administration for comment on its impact on small business.
Comments and Public Hearing
Before these Proposed Regulations are adopted as final regulations,
consideration will be given to any comments that are submitted timely
to the IRS as prescribed in this preamble under the ``Addresses''
heading. The IRS and the Treasury Department request comments on all
aspects of the proposed rules. All comments that are submitted by the
public will be available for public inspection and copying at
www.regulations.gov or upon request.
A public hearing has been scheduled for October 28, 2015, at 10:00
a.m., in the IRS Auditorium, Internal Revenue Service, 1111
Constitution Avenue NW., Washington, DC. Due to building security
procedures, visitors must enter at the Constitution Avenue entrance. In
addition, all visitors must present photo identification to enter the
building. Because of access restrictions, visitors will not be admitted
beyond the immediate entrance area more than 15 minutes before the
hearing starts. For more information about having your name placed on
the building access list to attend the hearing, see the FOR FURTHER
INFORMATION CONTACT section of this preamble.
The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who
wish to present oral comments at the hearing must submit written or
electronic comments and an outline of the topics to be discussed and
the time to be devoted to each topic by September 22, 2015. Such
persons should submit a signed paper original and eight (8) copies or
an electronic copy. A period of 10 minutes will be allotted to each
person for making comments. An agenda showing the scheduling of the
speakers will be prepared after the deadline for receiving outlines has
passed. Copies of the agenda will be available free of charge at the
hearing.
Drafting Information
The principal authors of these regulations are Johanna Som de Cerff
and Lewis Bell, Office of Associate Chief Counsel (Financial
Institutions and Products), IRS. However, other personnel from the IRS
and the Treasury Department participated in their development.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Partial Withdrawal of Notice of Proposed Rulemaking
Accordingly, under the authority of 26 U.S.C. 7805, Sec. 1.148-
1(f) of the notice of proposed rulemaking (REG-148659-07) that was
published in the Federal Register on September 16, 2013 (78 FR 56842),
is withdrawn.
Proposed Amendments to the Regulations
Accordingly, 26 CFR part 1 is proposed to be amended as follows:
PART 1--INCOME TAXES
0
Paragraph 1. The authority citation for part 1 continues to read in
part as follows:
Authority: 26 U.S.C. 7805 * * *
0
Par. 2. Section 1.148-0(c) is amended by adding entries for Sec. Sec.
1.148-1(f) and 1.148-11(m) to read as follows:
Sec. 1.148-0 Scope and table of contents.
* * * * *
(c) Table of contents. * * *
Sec. 1.148-1 Definitions and elections.
* * * * *
(f) Definition of issue price.
(1) In general.
(2) Bonds issued for money.
(3) Definitions.
(4) Special rules.
* * * * *
Sec. 1.148-11 Effective/applicability dates.
* * * * *
(m) Definition of issue price.
[[Page 36305]]
0
Par. 3. Section 1.148-1 is amended by revising the definition of issue
price in paragraph (b) and adding paragraph (f) to read as follows:
Sec. 1.148-1 Definitions and elections.
* * * * *
(b) * * *
Issue price means issue price as defined in paragraph (f) of this
section.
* * * * *
(f) Definition of issue price--(1) In general. Except as otherwise
provided in this paragraph (f), issue price is defined in sections 1273
and 1274 and the regulations under those sections.
(2) Bonds issued for money--(i) In general. The issue price of
bonds issued for money is the first price at which a substantial amount
of the bonds is sold to the public.
(ii) Alternative method based on initial offering price. As an
alternative to the general rule in paragraph (f)(2)(i) of this section,
if the underwriters have not received orders placed by the public for a
substantial amount of tax-exempt bonds on or before the sale date, the
issuer may treat the initial offering price to the public as the issue
price of the bonds if all of the following requirements are met:
(A) The underwriters fill all orders at the initial offering price
placed by the public and received by the underwriters on or before the
sale date (to the extent the orders do not exceed the amount of bonds
to be sold), and no underwriter fills an order placed by the public and
received by the underwriters on or before the sale date at a price
higher than the initial offering price.
(B) The issuer obtains from the lead underwriter in the
underwriting syndicate or selling group (or, if applicable, the sole
underwriter) certification of the following:
(1) The initial offering price;
(2) That the underwriters met the requirements of paragraph
(f)(2)(ii)(A) of this section;
(3) That no underwriter will fill an order placed by the public and
received after the sale date and before the issue date at a price
higher than the initial offering price, except if the higher price is
the result of a market change (such as a decline in interest rates) for
those bonds after the sale date; and
(4) That the lead (or sole) underwriter will provide the issuer
supporting documentation for the matters covered by the certifications
in paragraphs (f)(2)(ii)(B)(1) and (2) of this section and, with regard
to paragraph (f)(2)(ii)(B)(3) of this section, either documentation
regarding any bonds for which an underwriter filled an order placed by
the public and received after the sale date and before the issue date
at a price higher than the initial offering price and the corresponding
market change for those bonds, or a certification that no underwriter
filled such orders at a price higher than the initial offering price.
(C) The issuer does not know or have reason to know, after
exercising due diligence, that the certifications described in
paragraph (f)(2)(ii)(B) of this section are false.
(3) Definitions. For purposes of this paragraph (f), the following
definitions apply:
(i) Public. Public means any person (as defined in section
7701(a)(1)) other than an underwriter or a related party (as defined in
Sec. 1.150-1(b)) to an underwriter.
(ii) Underwriter. The term underwriter include--
(A) Any person (as defined in section 7701(a)(1)) that
contractually agrees to participate in the initial sale of the bonds to
the public by entering into a contract with the issuer (or with the
lead underwriter to form an underwriting syndicate); and
(B) Any person that, on or before the sale date, directly or
indirectly enters into a contract or other arrangement with a person
described in paragraph (f)(3)(ii)(A) of this section to sell the bonds.
(4) Special rules. For purposes of this paragraph (f), the
following special rules apply:
(i) Separate determinations. The issue price of bonds in an issue
that do not have the same credit and payment terms is determined
separately.
(ii) Substantial amount. Ten percent is a substantial amount.
(iii) Bonds issued for property. If a bond is issued for property,
the adjusted applicable Federal rate, as determined under section 1288,
is used in lieu of the applicable Federal rate to determine the bond's
issue price under section 1274.
0
Par. 4. Section 1.148-11 is amended by adding paragraph (m) to read as
follows:
Sec. 1.148-11 Effective/applicability dates.
* * * * *
(m) Definition of issue price. The definition of issue price in
Sec. 1.148-1(b) and (f) applies to bonds that are sold on or after the
date that is 90 days after the date of publication of the Treasury
decision adopting these rules as final regulations in the Federal
Register.
John M. Dalrymple,
Deputy Commissioner for Services and Enforcement.
[FR Doc. 2015-15411 Filed 6-23-15; 8:45 am]
BILLING CODE 4830-01-P