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Subject:
Item Title: ARBITRAGE REBATE COMPLIANCE
Summary:
Arbitrage rebate compliance has challenged issuers of tax-exempt debt since 1986.  With the passing of the Tax Reform Act of 1986, the Federal Government sought to limit the amount of investment income earned on unspent proceeds of tax-exempt financings.  The excess earnings, called arbitrage, result from the ability to obtain tax-exempt bond proceeds and invest the funds in higher yielding taxable securities, resulting in a profit.

The Arbitrage rebate requirements apply to virtually all issuers of tax-exempt financings including municipalities, airport and transportation, healthcare, higher education, water and wastewater, housing, sport facilities, convention centers and school districts.

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CIRCULAR 230 DISCLOSURE:

To ensure compliance with U.S. Treasury Department Regulations, we are required to advise you that, unless otherwise expressly indicated, any federal tax advice contained in this communication, including any attachments, is not intended or written by us to be used, and cannot be used, by anyone for the purpose of avoiding federal tax penalties.