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Table of Contents CommentsRE: Comments on Proposed Private Activity Bond Tests Regulations
Ladies and Gentlemen:
Enclosed please find the comments of Jones Hall Hill & White, A Professional Law Corporation regarding the proposed private activity bond regulations (FI-72-88). Jones Hall Hill & White acts solely as municipal bond counsel and underwriter's counsel with respect to the issuance of tax-exempt bonds by local government units in California. The firm provides opinions with respect to approximately 200 issues of municipal bonds in California each year and, as a consequence, is familiar with respect to a large variety of issues and issuers.
The undersigned authors act primarily as tax lawyers with respect to the tax-exempt bonds issued by local government units in California, and have particular experience with respect to federal issues regarding tax-exemption.
Mr. Walton has practiced as tax counsel in the area of municipal finance for over 12 years. During this period, he spent one and a half years as Counsel to the Assistant Chief Counsel (FI&P) at the Internal Revenue Service and two years as an Attorney Advisor in the office of Tax Policy at the United States Treasury. In his government capacities, he drafted legislation, regulations and published guidance with respect to section 103 of the Code. Mr. Walton is currently Chair of the Arbitrage and Rebate Committee of the National Association of Bond Lawyers.
Mrs. White has acted as bond counsel and special tax counsel for California bond issues for over 23 years. She was also President-Elect and President of the National Association of Bond Lawyers during the period from 1985 through 1987. In those capacities, she was closely involved in the review of the legislative history of the Tax Reform Act of 1986 as it was developed and in implementation of that Act by bond counsel throughout the country. In addition, on several occasions she was responsible for conducting Association seminars for Treasury Department representatives regarding the application of the private activity bond tests to local government bond issues. She was the author of the former publication "Handbook of Section 103 Rulings" and semiannual supplements. She is currently the author of a quarterly column entitled "Shared Tax Observations," relating to tax-exempt bonds.
The undersigned recognize that the enclosed comments are lengthy, but believe it important that the Treasury Department representatives are fully informed of the California State law relating to tax-exempt bonds, as well as matters in the legislative history of the Tax Reform Act of 1986 that were particularly negotiated so as to reflect the general State law of municipal bonds.
The undersigned appreciate the opportunity to comment and are willing to provide any assistance that may be requested by Treasury Department representatives to further explain the matters discussed in the comments.