Client Alert
On June 24, 2015, Prop. Treas. Reg. §1.148-1(f) addressing the definition of “Issue Price” was published in the Federal Register. The Internal Revenue Service is accepting comments on the Proposed Regulation through September 22, 2015. A public hearing is scheduled for October 28, 2015. While the Proposed Regulation is not now automatically applicable, the preamble to the Proposed Regulation specifically permits issuers to apply the Proposed Regulation to bonds sold on or after June 24, 2015 and before the day 90 days after the publication of final regulations on this matter. Regulations on the same subject matter were proposed in 2013 and withdrawn in 2015.
