Abstract

The IRS issued a revenue procedure that provides safe harbor conditions under which a management contract does not result in private business use of property financed with governmental tax‐exempt bonds or cause the modified private business use test for property financed with qualified 501(c)(3) bonds to be met (Rev. Proc. 2016‐44). This revenue procedure supersedes part or all of prior guidance (including the canonical Rev. Proc. 97‐13).

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