Notice 2008-80 proposes a revenue procedure that would modify Rev. Proc. 2003-84 by providing additional criteria that must be met in order for tax-exempt bond partnerships to be eligible to make an election that enables the partners to take into account monthly the inclusions required under Sections 702 and 707(c), including specifying a minimum gain share that must be paid upon disposition of the tax-exempt obligations and providing that the tax-exempt bond partnership must provide certain partners a right, exercisable by the date that represents 80% of the weighted average maturity of the bonds, to require a sale, redemption, or other disposition of the tax-exempt bonds held by the partnership. The proposed revenue procedure would also provide certain characteristics of tax-exempt bond partnerships, including noting that the put rights or guarantees for the benefit of certain partners of these partnerships are inapplicable in certain very limited circumstances.
and soundness collateral requirements as refinance qualified subprime loans. This take into account monthly the inclusions described therein. information will be used to quantify the required under §§ 702 and 707(c) of the In- An interpretive question has arisen use and carryforward of 2008 Housing ternal Revenue Code of 1986, as amended regarding the meaning of an “original is- Act Volume Cap and the refinancing of (the “Code”). The Treasury Department suance” during the relevant period and qualified subprime loans. The collections and the I
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