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Take Two – IRS Releases Revised Revenue Procedure on Management Contracts
The Revised Safe Harbor applies to any management contract with a service provider entered into on or after January 17, 2017 and may be applied to contracts entered into prior to this date. In addition, issuers may continue to apply Revenue Procedure 97-13 (as modified by Revenue Procedure 2001-39 and amplified by Notice 2014-67) to any management contract entered into before August 18, 2017. For contracts entered into after this date, only the rules, definitions and safe harbors outlined in the Revised Safe Harbor will apply to determine whether management contracts result in private business use of projects financed with tax-exempt obligations.
Posted: Jan 24, 2017