TEB Voluntary Compliance
Tax Exempt Bonds (TEB) focuses on providing participants in the municipal bond industry with quality service to assist issuers and conduit borrowers in understanding their tax responsibilities. As part of that service, TEB is providing the following general information for issuers of tax-exempt, tax credit, and direct pay bonds (tax-advantaged bonds) with respect to their post-issuance compliance responsibilities as well as voluntary compliance programs including remedial actions provided under the Income Tax Regulations and the TEB Voluntary Closing Agreement Program (TEB VCAP).
The educational resources provided below are intended to help issuers and other parties locate information and authoritative sources relating to voluntary compliance. The web-based information is not intended to be cited as an authoritative source. TEB recommends that issuers of tax-advantaged bonds review the authoritative sources referenced throughout these educational resources in consultation with their counsel.
Section 1 - Post-Issuance Compliance
This article provides general information on the post-issuance compliance responsibilities of issuers of tax-advantaged bonds. The on-going nature of post-issuance compliance responsibilities requires issuers to be diligent in identifying and resolving noncompliance, on a timely basis, to preserve the preferential status of tax-advantaged bonds.
Section 2 - TEB Self-Correction
This article provides general information on the availability of remedial action provisions under the Income Tax Regulations that issuers of tax-exempt bonds can use to resolve tax violations without the involvement of TEB.
Section 3 – TEB Private Letter Rulings
This article provides an overview description of private letter rulings, including important distinctions between private letter rulings and closing agreements related to tax-advantaged bonds. Revenue Procedure 2011-1 provides formal guidance on the process for requesting private letter rulings.
Section 4 - TEB VCAP Administrative Procedures
TEB administers TEB VCAP to assist issuers in conclusively resolving violations of the federal tax laws applicable to their tax-advantaged bonds in accordance with Notice 2008-31.
Section 5 - TEB VCAP Resolution Standards
TEB VCAP incorporates resolution standards in order to promote due diligence on the part of issuers and other parties to bond transactions in resolving violations of applicable federal tax laws by increasing the transparency of resolution methodologies and providing an economic incentive for issuers to timely identify violations and submit TEB VCAP requests.
- The TEB VCAP Resolution Standards article includes direct links to the various sections of IRM section 7.2.3 providing procedures relating to the resolution standards under TEB VCAP.
- The TEB VCAP Resolution Standards: Some Basic Concepts article provides general information and illustrative examples on the application of the resolution standards described in IRM section 18.104.22.168.
Section 6 – Feedback on TEB Voluntary Compliance
TEB invites issuers and other participants in the municipal bond industry to submit questions, comments and suggestions concerning its voluntary compliance programs. Please click here to send an email to TEB and include “TEB Voluntary Compliance” in the subject line of the email.