IRS released a timely private letter ruling PLR 202309014 on March 3 that analyzes foregoing factors. Private letter ruling deals with whether an issue of long-term working capital refinancing bonds was subject to proceeds-spent-last rule, issue overburdened tax-exempt bond market.
In this episode, we will describe the penalties imposed upon rule-breakers and the rewards offered to rule-followers. What happens if you have an abusive arbitrage device? What happens if you follow the arbitrage rules? What is the moral of the arbitrage story for issuers?