IRS Refines Rules for Tax-Free Bond Refunding Games
Published Date: 3/12/2026
Proposed Rule
Summary
The IRS is updating rules for tax-exempt refunding bonds to make things clearer and fairer for bond issuers. These changes affect how and when issuers can request refunds, handle transferred funds, and file important notices. If you deal with these bonds, get ready to review the new rules and send your comments by May 11, 2026—this could impact your money and paperwork!
Analyzed Economic Effects
8 provisions identified: 6 benefits, 2 costs, 0 mixed.
Longer Deadline to Claim Rebates
If you issue tax-advantaged bonds, you must request a refund of an overpayment no later than two years after either (A) the date that is 60 days after the final computation date for the issue, or (B) for the portion paid more than 60 days after the final computation date, the date that payment was made to the United States. This replaces the prior single two-year deadline tied only to the final computation date.
Valuation Rule for Transferred Proceeds
When proceeds of a prior issue become transferred proceeds of a refunding issue, the value of any nonpurpose investment allocated to those transferred proceeds on the transfer date may not exceed the value of that investment on the transfer date used for purposes of applying section 148 to the refunded issue. The rule clarifies that that valuation limit applies for all purposes of section 148.
Must Hold Funds On Cash-Outlay Date
To allocate gross proceeds from a specific source to an expenditure, those funds must be held by or on behalf of the issuer on the date of the cash outlay. This clarifies that funds received after the cash outlay cannot be retroactively allocated to that earlier outlay.
State Guarantee Fund Capacity Set at 500%
For certain State perpetual trust funds that guarantee tax-exempt bonds, the amount of bonds to be guaranteed plus previously guaranteed outstanding bonds may not exceed a total equal to 500 percent of the total costs of the assets held by the fund as of the sale date. This revision is in Sec. 1.148-11(d)(1)(F).
Special 90‑Day SLGS Added as Tax-Exempt Bond
A special 90-day certificate of indebtedness issued under the Demand Deposit State and Local Government Series program (31 CFR part 344) is added to the definition of 'tax-exempt bond' for purposes of section 148. This addresses involuntary conversions during a Treasury debt limit contingency.
Student‑Loan Refinancings Not Treated As Refunding
An issue is not a 'refunding issue' to the extent the actual issuer reasonably expects as of the issue date to use net proceeds within two years to refinance one or more qualified student loans. Also, 'proceeds' excludes investment proceeds received from investing in a qualified student loan or qualified mortgage loan for refunding determinations.
Update Where to File Bond Notices
The regulation deletes an outdated IRS street address and allows filing locations to be designated by guidance published in the Internal Revenue Bulletin or on the IRS website (for example, https://www.irs.gov/bondsmailing). This change is proposed to apply to notices and elections filed after the date 30 days after publication of final regulations.
Removal of Former 150% Debt Service Limit
The proposed regulations remove existing Sec. 1.148-2(f)(2)(iv), which related to the former statutory limitation in section 148(d)(3) (a former 150 percent debt service limitation) applying to bonds issued on or before August 5, 1997. The removal applies as of the date of publication of final regulations in the Federal Register.
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