Res No 054-25-16346RESOLUTION NO.054-25-16346
A RESOLUTION OF THE MAYOR AND COMMISSION OF
THE CITY OF SOUTH MIAMI,FLORIDA,INDICATING
THE CITY’S OFFICIAL INTENT TO ISSUE TAX-EXEMPT
BONDS IN AN AMOUNT NOT TO EXCEED $35,000,000 TO
FINANCE THE COSTS OF ACQUIRING,CONSTRUCTING,
RECONSTRUCTING,IMPROVING AND EQUIPPING
VARIOUS CAPITAL IMPROVEMENTS,REAL PROPERTY,
AND INFRASTRUCTURE FOR PARKS AND RECREATION,
PUBLIC WORKS,AND PUBLIC SAFETY WITHIN THE
CITY OF SOUTH MIAMI AND TO USE A PORTION OF THE
PROCEEDS OF SUCH BONDS TO REIMBURSE
EXPENDITURES PAID OR INCURRED PRIOR TO THE
DATE OF ISSUANCE THEREOF;AND PROVIDING FOR
IMPLEMENTATION,CORRECTIONS AND AN EFFECTIVE
DATE.
WHEREAS,the City of South Miami,Florida (the “City”)has determined that acquiring,
constructing,reconstructing,improving and equipping various capital improvements,real
property,and infrastructure for parks and recreation,public works,and public safety (the
“Improvements”)is in the best interest of the City;and
WHEREAS,the City intends to issue tax-exempt bonds (the “Bonds”)for the purpose of
financing the costs of the Improvements;and
WHEREAS,a portion of the costs of the Improvements may be paid before the Bonds are
issued in anticipation of the reimbursement of such expenditures from proceeds of the Bonds;and
WHEREAS,Section 1.150-2 of the Federal income tax regulations requires the City to
officially declare its intent to use proceeds of the Bonds to reimburse expenditures paid prior to
issuance thereof as a prerequisite to the proceeds being treated as used for reimbursement purposes;
and
WHEREAS,the City Commission finds that the adoption of this Resolution is in the best
interest and welfare of the residents of the City.
NOW,THEREFORE,BE IT RESOLVED BY THE MAYOR AND CITY
COMMISSION OF THE CITY OF SOUTH MIAMI,FLORIDA,AS FOLLOWS:
Section 1.Recitals.The above-stated recitals are true and correct and are
incorporated herein by this reference.
Section 2.Expression of Intent.The City Commission intends to issue tax-exempt
Bonds in the amount necessary to finance the costs of the Improvements.The maximum principal
amount of the Bonds expected to be issued for the Improvement is $35,000,000.This Resolution does
Res.No.054-25-16346
not commit the City to issue the Bonds,but is adopted solely for the purposes of complying with the
requirements of the Code of Federal Regulations,Title 26,§1.150-2.No bonds are being issued
hereby.The issuance of the Bonds shall be subject to subsequent ordinance or resolution of the City
Commission.
Section 3.Implementation.The City Manager and City Officials are hereby
authorized to take any and all actions necessary to implement the purposes of this Resolution.
Section 4.Corrections.Conforming language or technical scrivener-type corrections
may be made by the City Attorney for any conforming amendments to be incorporated into the
final resolution for signature.
Section 5.Effective Date.This Resolution shall take effect immediately upon
adoption.
PASSED AND ADOPTED this 29th day of July,2025.
ATTEST:
READ AND APPROVED AS TO FORM,
LANGUAGE,LEGALITY AND
EXECUTION THEREOF
WEISS SEROTA HELFMAN COLE
&BIERMAN,P.L.
CITY ATTORNEY
APPROVED:
MAYOR
COMMISSION VOTE:4-1
Mayor Javier Fernandez:Yea
Vice Mayor Brian Corey:Yea
Commissioner Steve Calle:Yea
Commissioner Danny Rodriguez;Yea
Commissioner Lisa Bonich:Nay
Page 2 of 2
Subject:
Suggested Action:
Meeting Date:July 29, 2025
Submitted By:Nkenga Payne
Submitted Department:Finance Department
Item Type:Resolution
Agenda Section:CONSENT AGENDA
A RESOLUTION OF THE MAYOR AND COMMISSION OF
THE CITY OF SOUTH MIAMI, FLORIDA, INDICATING THE
CITY’S OFFICIAL INTENT TO ISSUE TAX-EXEMPT
BONDS IN AN AMOUNT NOT TO EXCEED $10,000,000 TO
FINANCE THE COSTS OF ACQUIRING, CONSTRUCTING,
RECONSTRUCTING, IMPROVING AND EQUIPPING
VARIOUS CAPITAL IMPROVEMENTS, REAL PROPERTY,
AND INFRASTRUCTURE FOR PARKS AND RECREATION,
PUBLIC WORKS, AND PUBLIC SAFETY WITHIN THE CITY
OF SOUTH MIAMI AND TO USE A PORTION OF THE
PROCEEDS OF SUCH BONDS TO REIMBURSE
EXPENDITURES PAID OR INCURRED PRIOR TO THE
DATE OF ISSUANCE THEREOF; AND PROVIDING FOR
IMPLEMENTATION, CORRECTIONS AND AN EFFECTIVE
DATE. 3/5 (CITY MANAGER-FINANCE DEPT.)
Agenda Item No. 1.
CITY COMMISSION Agenda Item Report
Attachments:
CM_Memo_Reimbursement_Resolution_2025__1_.docx
4BJ8978-Resolution_Declaring_Intent_to_Issue_Tax-Exempt_Bonds__10m_2025_CAv2.docx
CFR-2020-title26-vol3-sec1-150-2.pdf
1
CITY OF SOUTH MIAMI
OFFICE OF THE CITY MANAGER
INTER-OFFICE MEMORANDUM
TO: The Honorable Mayor, Vice Mayor, and Members of the City Commission
FROM: Genaro “Chip” Iglesias, City Manager
DATE: July 29, 2025
Subject: Possible Future Issuance of Tax-Exempt Bonds and Reimbursement of Prior
Expenditures
RECOMMENDATION: Adoption of a reimbursement resolution that would allow the City of South
Miami to preserve the ability to use future tax-exempt bond proceeds to
reimburse itself for eligible costs associated with capital projects. These
expenses may be incurred in advance of any future financing decisions.
This resolution does not state or imply that the City will issue debt. It simply
ensures that, if the Commission decides to issue tax-exempt bonds, the
City would be able to include prior eligible expenditures in that financing.
Without this resolution, those earlier costs could not be reimbursed
using bond proceeds.
BACKGROUND: The City is moving forward with several capital improvement initiative s
designed to enhance public spaces and community infrastructure.
Some planning, design, and pre-acquisition work for these projects may
begin before any financing decision is made. Under IRS regulations (Section
1.150-2), the City must adopt a reimbursement resolution before incurring
such costs if it wishes to preserve the right to reimburse them later using
tax-exempt bond proceeds.
PURPOSE: This resolution is a procedural safeguard—not a financial decision. It
protects the City’s flexibility without committing it to any future action.
Specifically:
Maintains IRS Eligibility: The IRS requires this resolution to be in
place before funds are spent in order for those costs to be eligible
for reimbursement with tax-exempt bond proceeds later.
2
South^'Miami
THE CITY OF PLEASANT LIVING
CITY OF SOUTH MIAMI
OFFICE OF THE CITY MANAGER
INTER-OFFICE MEMORANDUM
Reimbursement Timeframe: Once adopted, the resolution allows
the City to reimburse itself for qualified costs paid up to 18 months
prior to the bond issuance, and no later than three years from the
date the original expense is incurred. These deadlines are defined
by federal regulation and are strictly enforced.
Protects Project Timelines: Projects and property acquisitions, like
the Manor Lane parcel, may require action ahead of formal bond
issuance. This resolution ensures the City isn’t locked out of using
bond proceeds to cover those earlier costs.
No Commitment to Borrowing: Again, this resolution does not
authorize or require the City to issue bonds. It simply preserves the
option to do so in the future while retaining the ability to include
already-incurred project costs.
Supports Financial Best Practices: This is a common, prudent
planning step used by many cities and counties when preparing for
possible long-term financing.
If approved, this resolution will preserve the City’s flexibility to finance any
design or preliminary project work completed, should the Commission
later determine that issuing debt is in the City’s best interest. At that time,
a separate ordinance would be required and presented for formal approval
of any financing.
ATTACHMENTS: Proposed Resolution
CFR-2020-title26-vol3-sec1-150-2
3
South^'Miami
THE CITY OF PLEASANT LIVING
165
Internal Revenue Service, Treasury §1.150–2
(4) Advance refunding issue. Advance
refunding issue means a refunding issue
that is not a current refunding issue.
(5) Prior issue. Prior issue means an
issue of obligations all or a portion of
the principal, interest, or call premium
on which is paid or provided for with
proceeds of a refunding issue. A prior
issue may be issued before, at the same
time as, or after a refunding issue. If
the refunded and unrefunded portions
of a prior issue are treated as separate
issues under §1.148–9(i), for the pur-
poses for which that section applies,
except to the extent that the context
clearly requires otherwise, references
to a prior issue refer only to the re-
funded portion of that prior issue.
(e) Controlled group means a group of
entities controlled directly or indi-
rectly by the same entity or group of
entities within the meaning of this
paragraph (e).
(1) Direct control. The determination
of direct control is made on the basis of
all the relevant facts and cir-
cumstances. One entity or group of en-
tities (the controlling entity) generally
controls another entity or group of en-
tities (the controlled entity) for purposes
of this paragraph if the controlling en-
tity possesses either of the following
rights or powers and the rights or pow-
ers are discretionary and non-ministe-
rial—
(i) The right or power both to ap-
prove and to remove without cause a
controlling portion of the governing
body of the controlled entity; or
(ii) The right or power to require the
use of funds or assets of the controlled
entity for any purpose of the control-
ling entity.
(2) Indirect control. If a controlling en-
tity controls a controlled entity under
the test in paragraph (e)(1) of this sec-
tion, then the controlling entity also
controls all entities controlled, di-
rectly or indirectly, by the controlled
entity or entities.
(3) Exception for general purpose gov-
ernmental entities. An entity is not a
controlled entity under this paragraph
(e) if the entity possesses substantial
taxing, eminent domain, and police
powers. For example, a city possessing
substantial amounts of each of these
sovereign powers is not a controlled en-
tity of the state.
(f) Definition and treatment of grants—
(1) Definition. Grant means a transfer
for a governmental purpose of money
or property to a transferee that is not
a related party to or an agent of the
transferor. The transfer must not im-
pose any obligation or condition to di-
rectly or indirectly repay any amount
to the transferor or a related party.
Obligations or conditions intended
solely to assure expenditure of the
transferred moneys in accordance with
the governmental purpose of the trans-
fer do not prevent a transfer from
being a grant.
(2) Treatment. Except as otherwise
provided (for example, §1.148–6(d)(4),
which treats proceeds used for grants
as spent for arbitrage purposes when
the grant is made), the character and
nature of a grantee’s use of proceeds
are taken into account in determining
which rules are applicable to the bond
issue and whether the applicable re-
quirements for the bond issue are met.
For example, a grantee’s use of pro-
ceeds generally determines whether the
proceeds are used for capital projects
or working capital expenditures under
section 148 and whether the qualified
purposes for the specific type of bond
issue are met.
[T.D. 8476, 58 FR 33549, June 18, 1993; 58 FR
44453, Aug. 23, 1993, as amended by T.D. 8538,
59 FR 24046, May 10, 1994; T.D. 8712, 62 FR
2304, Jan. 16, 1997; T.D. 8718, 62 FR 25513, May
9, 1997; T.D. 9234, 70 FR 75036, Dec. 19, 2005;
T.D. 9533, 76 FR 39280, July 6, 2011; T.D. 9637,
78 FR 54759, Sept. 6, 2013; T.D. 9777, 81 FR
46598, July 18, 2016]
§1.150–2 Proceeds of bonds used for
reimbursement.
(a) Table of contents. This table of
contents contains a listing of the head-
ings contained in §1.150–2.
(a) Table of contents.
(b) Scope.
(c) Definitions.
(d) General operating rules for reimburse-
ment expenditures.
(1) Official intent.
(2) Reimbursement period.
(3) Nature of expenditure.
(e) Official intent rules.
(1) Form of official intent.
(2) Project description in official intent.
(3) Reasonableness of official intent.
(f) Exceptions to general operating rules.
(1) De minimis exception.
(2) Preliminary expenditures exception.
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166
26 CFR Ch. I (4–1–20 Edition) §1.150–2
(g) Special rules on refundings.
(1) In general—once financed, not reim-
bursed.
(2) Certain proceeds of prior issue used for
reimbursement treated as unspent.
(h) Anti-abuse rules.
(1) General rule.
(2) One-year step transaction rule.
(i) Authority of the Commissioner to pre-
scribe rules.
(j) Effective date.
(1) In general.
(2) Transitional rules.
(3) Nature of expenditure.
(b) Scope. This section applies to re-
imbursement bonds (as defined in para-
graph (c) of this section) for all pur-
poses of sections 103 and 141 to 150.
(c) Definitions. The following defini-
tions apply:
Issuer means—
(1) For any private activity bond (ex-
cluding a qualified 501(c)(3) bond, quali-
fied student loan bond, qualified mort-
gage bond, or qualified veterans’ mort-
gage bond), the entity that actually
issues the reimbursement bond; and
(2) For any bond not described in
paragraph (1) of this definition, either
the entity that actually issues the re-
imbursement bond or, to the extent
that the reimbursement bond proceeds
are to be loaned to a conduit borrower,
that conduit borrower.
Official intent means an issuer’s dec-
laration of intent to reimburse an
original expenditure with proceeds of
an obligation.
Original expenditure means an expend-
iture for a governmental purpose that
is originally paid from a source other
than a reimbursement bond.
Placed in service means, with respect
to a facility, the date on which, based
on all the facts and circumstances—
(1) The facility has reached a degree
of completion which would permit its
operation at substantially its design
level; and
(2) The facility is, in fact, in oper-
ation at such level.
Reimbursement allocation means an al-
location in writing that evidences an
issuer’s use of proceeds of a reimburse-
ment bond to reimburse an original ex-
penditure. An allocation made within
30 days after the issue date of a reim-
bursement bond may be treated as
made on the issue date.
Reimbursement bond means the por-
tion of an issue allocated to reimburse
an original expenditure that was paid
before the issue date.
(d) General operating rules for reim-
bursement expenditures. Except as other-
wise provided, a reimbursement alloca-
tion is treated as an expenditure of
proceeds of a reimbursement bond for
the governmental purpose of the origi-
nal expenditure on the date of the re-
imbursement allocation only if:
(1) Official intent. Not later than 60
days after payment of the original ex-
penditure, the issuer adopts an official
intent for the original expenditure that
satisfies paragraph (e) of this section.
(2) Reimbursement period—(i) In gen-
eral. The reimbursement allocation is
made not later than 18 months after
the later of—
(A) The date the original expenditure
is paid; or
(B) The date the project is placed in
service or abandoned, but in no event
more than 3 years after the original ex-
penditure is paid.
(ii) Special rule for small issuers. In ap-
plying paragraph (d)(2)(i) of this sec-
tion to an issue that satisfies section
148(f)(4)(D)(i) (I) through (IV), the ‘‘18
month’’ limitation is changed to ‘‘3
years’’ and the ‘‘3-year’’ maximum re-
imbursement period is disregarded.
(iii) Special rule for long-term construc-
tion projects. In applying paragraph
(d)(2)(i) to a construction project for
which both the issuer and a licensed ar-
chitect or engineer certify that at least
5 years is necessary to complete con-
struction of the project, the maximum
reimbursement period is changed from
‘‘3 years’’ to ‘‘5 years.’’
(3) Nature of expenditure. The original
expenditure is a capital expenditure, a
cost of issuance for a bond, an expendi-
ture described in §1.148–6(d)(3)(ii)(B)
(relating to certain extraordinary
working capital items), a grant (as de-
fined in §1.150–1(f)), a qualified student
loan, a qualified mortgage loan, or a
qualified veterans’ mortgage loan.
(e) Official intent rules. An official in-
tent satisfies this paragraph (e) if:
(1) Form of official intent. The official
intent is made in any reasonable form,
including issuer resolution, action by
an appropriate representative of the
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167
Internal Revenue Service, Treasury §1.150–2
issuer (e.g., a person authorized or des-
ignated to declare official intent on be-
half of the issuer), or specific legisla-
tive authorization for the issuance of
obligations for a particular project.
(2) Project description in official in-
tent—(i) In general. The official intent
generally describes the project for
which the original expenditure is paid
and states the maximum principal
amount of obligations expected to be
issued for the project. A project in-
cludes any property, project, or pro-
gram (e.g., highway capital improvement
program, hospital equipment acquisition,
or school building renovation).
(ii) Fund accounting. A project de-
scription is sufficient if it identifies, by
name and functional purpose, the fund
or account from which the original ex-
penditure is paid (e.g., parks and recre-
ation fund—recreational facility capital
improvement program).
(iii) Reasonable deviations in project
description. Deviations between a
project described in an official intent
and the actual project financed with
reimbursement bonds do not invalidate
the official intent to the extent that
the actual project is reasonably related
in function to the described project.
For example, hospital equipment is a
reasonable deviation from hospital
building improvements. In contrast, a
city office building rehabilitation is not a
reasonable deviation from highway im-
provements.
(3) Reasonableness of official intent. On
the date of the declaration, the issuer
must have a reasonable expectation (as
defined in §1.148–1(b)) that it will reim-
burse the original expenditure with
proceeds of an obligation. Official in-
tents declared as a matter of course or
in amounts substantially in excess of
the amounts expected to be necessary
for the project (e.g., blanket declara-
tions) are not reasonable. Similarly, a
pattern of failure to reimburse actual
original expenditures covered by offi-
cial intents (other than in extraor-
dinary circumstances) is evidence of
unreasonableness. An official intent
declared pursuant to a specific legisla-
tive authorization is rebuttably pre-
sumed to satisfy this paragraph (e)(3).
(f) Exceptions to general operating
rules—(1) De minimis exception. Para-
graphs (d)(1) and (d)(2) of this section
do not apply to costs of issuance of any
bond or to an amount not in excess of
the lesser of $100,000 or 5 percent of the
proceeds of the issue.
(2) Preliminary expenditures exception.
Paragraphs (d)(1) and (d)(2) of this sec-
tion do not apply to any preliminary
expenditures, up to an amount not in
excess of 20 percent of the aggregate
issue price of the issue or issues that fi-
nance or are reasonably expected by
the issuer to finance the project for
which the preliminary expenditures
were incurred. Preliminary expendi-
tures include architectural, engineer-
ing, surveying, soil testing, reimburse-
ment bond issuance, and similar costs
that are incurred prior to commence-
ment of acquisition, construction, or
rehabilitation of a project, other than
land acquisition, site preparation, and
similar costs incident to commence-
ment of construction.
(g) Special rules on refundings—(1) In
general—once financed, not reimbursed.
Except as provided in paragraph (g)(2)
of this section, paragraph (d) of this
section does not apply to an allocation
to pay principal or interest on an obli-
gation or to reimburse an original ex-
penditure paid by another obligation.
Instead, such an allocation is analyzed
under rules on refunding issues. See
§1.148–9.
(2) Certain proceeds of prior issue used
for reimbursement treated as unspent. In
the case of a refunding issue (or series
of refunding issues), proceeds of a prior
issue purportedly used to reimburse
original expenditures are treated as
unspent proceeds of the prior issue un-
less the purported reimbursement was
a valid expenditure under applicable
law on reimbursement expenditures on
the issue date of the prior issue.
(h) Anti-abuse rules—(1) General rule.
A reimbursement allocation is not an
expenditure of proceeds of an issue
under this section if the allocation em-
ploys an abusive arbitrage device under
§1.148–10 to avoid the arbitrage restric-
tions or to avoid the restrictions under
sections 142 through 147.
(2) One-year step transaction rule—(i)
Creation of replacement proceeds. A pur-
ported reimbursement allocation is in-
valid and thus is not an expenditure of
proceeds of an issue if, within 1 year
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168
26 CFR Ch. I (4–1–20 Edition) §1.150–4
after the allocation, funds cor-
responding to the proceeds of a reim-
bursement bond for which a reimburse-
ment allocation was made are used in a
manner that results in the creation of
replacement proceeds (as defined in
§1.148–1) of that issue or another issue.
The preceding sentence does not apply
to amounts deposited in a bona fide
debt service fund (as defined in §1.148–
1).
(ii) Example. The provisions of para-
graph (h)(2)(i) of this section are illus-
trated by the following example.
Example. On January 1, 1994, County A
issues an issue of 7 percent tax-exempt bonds
(the 1994 issue) and makes a purported reim-
bursement allocation to reimburse an origi-
nal expenditure for specified capital im-
provements. A immediately deposits funds
corresponding to the proceeds subject to the
reimbursement allocation in an escrow fund
to provide for payment of principal and in-
terest on its outstanding 1991 issue of 9 per-
cent tax-exempt bonds (the prior issue). The
use of amounts corresponding to the pro-
ceeds of the reimbursement bonds to create a
sinking fund for another issue within 1 year
after the purported reimbursement alloca-
tion invalidates the reimbursement alloca-
tion. The proceeds retain their character as
unspent proceeds of the 7 percent issue upon
deposit in the escrow fund. Accordingly, the
proceeds are subject to the 7 percent yield
restriction of the 1994 issue instead of the 9
percent yield restriction of the prior issue.
(i) Authority of the Commissioner to
prescribe rules. The Commissioner may
by revenue ruling or revenue procedure
(see §601.601(d)(2)(ii)(b) of this chapter)
prescribe rules for the expenditure of
proceeds of reimbursement bonds in
circumstances that do not otherwise
satisfy this section.
(j) Effective date—(1) In general. Ex-
cept as otherwise provided, the provi-
sions of this section apply to all alloca-
tions of proceeds of reimbursement
bonds issued after June 30, 1993.
(2) Transitional rules—(i) Official in-
tent. An official intent is treated as
satisfying the official intent require-
ment of paragraph (d)(1) of this section
if it—
(A) Satisfied the applicable provi-
sions of §1.103–8(a)(5) as in effect prior
to July 1, 1993, (as contained in 26 CFR
part 1 revised as of April 1, 1993) and
was made prior to that date, or
(B) Satisfied the applicable provi-
sions of §1.103–18 as in effect between
January 27, 1992, and June 30, 1993, (as
contained in 26 CFR part 1 revised as of
April 1, 1993) and was made during that
period.
(ii) Certain expenditures of private ac-
tivity bonds. For any expenditure that
was originally paid prior to August 15,
1993, and that would have qualified for
expenditure by reimbursement from
the proceeds of a private activity bond
under T.D. 7199, section 1.103–8(a)(5),
1972–2 C.B. 45 (see §601.601(d)(2)(ii)(b)) of
this chapter, the requirements of that
section may be applied in lieu of this
section.
(3) Nature of expenditure. Paragraph
(d)(3) of this section applies to bonds
that are sold on or after October 17,
2016.
[T.D. 8476, 58 FR 33551, June 18, 1993; 58 FR
44453, Aug. 23, 1993; T.D. 9777, 81 FR 46598,
July 18, 2016]
§1.150–4 Change in use of facilities fi-
nanced with tax-exempt private ac-
tivity bonds.
(a) Scope. This section applies for
purposes of the rules for change of use
of facilities financed with private ac-
tivity bonds under sections 150(b)(3)
(relating to qualified 501(c)(3) bonds),
150(b)(4) (relating to certain exempt fa-
cility bonds and small issue bonds),
150(b)(5) (relating to facilities required
to be owned by governmental units or
501(c)(3) organizations), and 150(c).
(b) Effect of remedial actions—(1) In
general. Except as provided in this sec-
tion, the change of use provisions of
sections 150(b) (3) through (5), and
150(c) apply even if the issuer takes a
remedial action described in §§1.142–2,
1.144–2, or 1.145–2.
(2) Exceptions—(i) Redemption. If non-
qualified bonds are redeemed within 90
days of a deliberate action under
§1.145–2(a) or within 90 days of the date
on which a failure to properly use pro-
ceeds occurs under §1.142–2 or §1.144–2,
sections 150(b) (3) through (5) do not
apply during the period between that
date and the date on which the non-
qualified bonds are redeemed.
(ii) Alternative qualifying use of facil-
ity. If a bond-financed facility is used
for an alternative qualifying use under
§§1.145–2 and 1.141–12(f), sections 150(b)
(3) and (5) do not apply because of the
alternative use.
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165
Internal Revenue Service, Treasury §1.150–2
(4) Advance refunding issue. Advance
refunding issue means a refunding issue
that is not a current refunding issue.
(5) Prior issue. Prior issue means an
issue of obligations all or a portion of
the principal, interest, or call premium
on which is paid or provided for with
proceeds of a refunding issue. A prior
issue may be issued before, at the same
time as, or after a refunding issue. If
the refunded and unrefunded portions
of a prior issue are treated as separate
issues under §1.148–9(i), for the pur-
poses for which that section applies,
except to the extent that the context
clearly requires otherwise, references
to a prior issue refer only to the re-
funded portion of that prior issue.
(e) Controlled group means a group of
entities controlled directly or indi-
rectly by the same entity or group of
entities within the meaning of this
paragraph (e).
(1) Direct control. The determination
of direct control is made on the basis of
all the relevant facts and cir-
cumstances. One entity or group of en-
tities (the controlling entity) generally
controls another entity or group of en-
tities (the controlled entity) for purposes
of this paragraph if the controlling en-
tity possesses either of the following
rights or powers and the rights or pow-
ers are discretionary and non-ministe-
rial—
(i) The right or power both to ap-
prove and to remove without cause a
controlling portion of the governing
body of the controlled entity; or
(ii) The right or power to require the
use of funds or assets of the controlled
entity for any purpose of the control-
ling entity.
(2) Indirect control. If a controlling en-
tity controls a controlled entity under
the test in paragraph (e)(1) of this sec-
tion, then the controlling entity also
controls all entities controlled, di-
rectly or indirectly, by the controlled
entity or entities.
(3) Exception for general purpose gov-
ernmental entities. An entity is not a
controlled entity under this paragraph
(e) if the entity possesses substantial
taxing, eminent domain, and police
powers. For example, a city possessing
substantial amounts of each of these
sovereign powers is not a controlled en-
tity of the state.
(f) Definition and treatment of grants—
(1) Definition. Grant means a transfer
for a governmental purpose of money
or property to a transferee that is not
a related party to or an agent of the
transferor. The transfer must not im-
pose any obligation or condition to di-
rectly or indirectly repay any amount
to the transferor or a related party.
Obligations or conditions intended
solely to assure expenditure of the
transferred moneys in accordance with
the governmental purpose of the trans-
fer do not prevent a transfer from
being a grant.
(2) Treatment. Except as otherwise
provided (for example, §1.148–6(d)(4),
which treats proceeds used for grants
as spent for arbitrage purposes when
the grant is made), the character and
nature of a grantee’s use of proceeds
are taken into account in determining
which rules are applicable to the bond
issue and whether the applicable re-
quirements for the bond issue are met.
For example, a grantee’s use of pro-
ceeds generally determines whether the
proceeds are used for capital projects
or working capital expenditures under
section 148 and whether the qualified
purposes for the specific type of bond
issue are met.
[T.D. 8476, 58 FR 33549, June 18, 1993; 58 FR
44453, Aug. 23, 1993, as amended by T.D. 8538,
59 FR 24046, May 10, 1994; T.D. 8712, 62 FR
2304, Jan. 16, 1997; T.D. 8718, 62 FR 25513, May
9, 1997; T.D. 9234, 70 FR 75036, Dec. 19, 2005;
T.D. 9533, 76 FR 39280, July 6, 2011; T.D. 9637,
78 FR 54759, Sept. 6, 2013; T.D. 9777, 81 FR
46598, July 18, 2016]
§1.150–2 Proceeds of bonds used for
reimbursement.
(a) Table of contents. This table of
contents contains a listing of the head-
ings contained in §1.150–2.
(a) Table of contents.
(b) Scope.
(c) Definitions.
(d) General operating rules for reimburse-
ment expenditures.
(1) Official intent.
(2) Reimbursement period.
(3) Nature of expenditure.
(e) Official intent rules.
(1) Form of official intent.
(2) Project description in official intent.
(3) Reasonableness of official intent.
(f) Exceptions to general operating rules.
(1) De minimis exception.
(2) Preliminary expenditures exception.
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26 CFR Ch. I (4–1–20 Edition) §1.150–2
(g) Special rules on refundings.
(1) In general—once financed, not reim-
bursed.
(2) Certain proceeds of prior issue used for
reimbursement treated as unspent.
(h) Anti-abuse rules.
(1) General rule.
(2) One-year step transaction rule.
(i) Authority of the Commissioner to pre-
scribe rules.
(j) Effective date.
(1) In general.
(2) Transitional rules.
(3) Nature of expenditure.
(b) Scope. This section applies to re-
imbursement bonds (as defined in para-
graph (c) of this section) for all pur-
poses of sections 103 and 141 to 150.
(c) Definitions. The following defini-
tions apply:
Issuer means—
(1) For any private activity bond (ex-
cluding a qualified 501(c)(3) bond, quali-
fied student loan bond, qualified mort-
gage bond, or qualified veterans’ mort-
gage bond), the entity that actually
issues the reimbursement bond; and
(2) For any bond not described in
paragraph (1) of this definition, either
the entity that actually issues the re-
imbursement bond or, to the extent
that the reimbursement bond proceeds
are to be loaned to a conduit borrower,
that conduit borrower.
Official intent means an issuer’s dec-
laration of intent to reimburse an
original expenditure with proceeds of
an obligation.
Original expenditure means an expend-
iture for a governmental purpose that
is originally paid from a source other
than a reimbursement bond.
Placed in service means, with respect
to a facility, the date on which, based
on all the facts and circumstances—
(1) The facility has reached a degree
of completion which would permit its
operation at substantially its design
level; and
(2) The facility is, in fact, in oper-
ation at such level.
Reimbursement allocation means an al-
location in writing that evidences an
issuer’s use of proceeds of a reimburse-
ment bond to reimburse an original ex-
penditure. An allocation made within
30 days after the issue date of a reim-
bursement bond may be treated as
made on the issue date.
Reimbursement bond means the por-
tion of an issue allocated to reimburse
an original expenditure that was paid
before the issue date.
(d) General operating rules for reim-
bursement expenditures. Except as other-
wise provided, a reimbursement alloca-
tion is treated as an expenditure of
proceeds of a reimbursement bond for
the governmental purpose of the origi-
nal expenditure on the date of the re-
imbursement allocation only if:
(1) Official intent. Not later than 60
days after payment of the original ex-
penditure, the issuer adopts an official
intent for the original expenditure that
satisfies paragraph (e) of this section.
(2) Reimbursement period—(i) In gen-
eral. The reimbursement allocation is
made not later than 18 months after
the later of—
(A) The date the original expenditure
is paid; or
(B) The date the project is placed in
service or abandoned, but in no event
more than 3 years after the original ex-
penditure is paid.
(ii) Special rule for small issuers. In ap-
plying paragraph (d)(2)(i) of this sec-
tion to an issue that satisfies section
148(f)(4)(D)(i) (I) through (IV), the ‘‘18
month’’ limitation is changed to ‘‘3
years’’ and the ‘‘3-year’’ maximum re-
imbursement period is disregarded.
(iii) Special rule for long-term construc-
tion projects. In applying paragraph
(d)(2)(i) to a construction project for
which both the issuer and a licensed ar-
chitect or engineer certify that at least
5 years is necessary to complete con-
struction of the project, the maximum
reimbursement period is changed from
‘‘3 years’’ to ‘‘5 years.’’
(3) Nature of expenditure. The original
expenditure is a capital expenditure, a
cost of issuance for a bond, an expendi-
ture described in §1.148–6(d)(3)(ii)(B)
(relating to certain extraordinary
working capital items), a grant (as de-
fined in §1.150–1(f)), a qualified student
loan, a qualified mortgage loan, or a
qualified veterans’ mortgage loan.
(e) Official intent rules. An official in-
tent satisfies this paragraph (e) if:
(1) Form of official intent. The official
intent is made in any reasonable form,
including issuer resolution, action by
an appropriate representative of the
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Internal Revenue Service, Treasury §1.150–2
issuer (e.g., a person authorized or des-
ignated to declare official intent on be-
half of the issuer), or specific legisla-
tive authorization for the issuance of
obligations for a particular project.
(2) Project description in official in-
tent—(i) In general. The official intent
generally describes the project for
which the original expenditure is paid
and states the maximum principal
amount of obligations expected to be
issued for the project. A project in-
cludes any property, project, or pro-
gram (e.g., highway capital improvement
program, hospital equipment acquisition,
or school building renovation).
(ii) Fund accounting. A project de-
scription is sufficient if it identifies, by
name and functional purpose, the fund
or account from which the original ex-
penditure is paid (e.g., parks and recre-
ation fund—recreational facility capital
improvement program).
(iii) Reasonable deviations in project
description. Deviations between a
project described in an official intent
and the actual project financed with
reimbursement bonds do not invalidate
the official intent to the extent that
the actual project is reasonably related
in function to the described project.
For example, hospital equipment is a
reasonable deviation from hospital
building improvements. In contrast, a
city office building rehabilitation is not a
reasonable deviation from highway im-
provements.
(3) Reasonableness of official intent. On
the date of the declaration, the issuer
must have a reasonable expectation (as
defined in §1.148–1(b)) that it will reim-
burse the original expenditure with
proceeds of an obligation. Official in-
tents declared as a matter of course or
in amounts substantially in excess of
the amounts expected to be necessary
for the project (e.g., blanket declara-
tions) are not reasonable. Similarly, a
pattern of failure to reimburse actual
original expenditures covered by offi-
cial intents (other than in extraor-
dinary circumstances) is evidence of
unreasonableness. An official intent
declared pursuant to a specific legisla-
tive authorization is rebuttably pre-
sumed to satisfy this paragraph (e)(3).
(f) Exceptions to general operating
rules—(1) De minimis exception. Para-
graphs (d)(1) and (d)(2) of this section
do not apply to costs of issuance of any
bond or to an amount not in excess of
the lesser of $100,000 or 5 percent of the
proceeds of the issue.
(2) Preliminary expenditures exception.
Paragraphs (d)(1) and (d)(2) of this sec-
tion do not apply to any preliminary
expenditures, up to an amount not in
excess of 20 percent of the aggregate
issue price of the issue or issues that fi-
nance or are reasonably expected by
the issuer to finance the project for
which the preliminary expenditures
were incurred. Preliminary expendi-
tures include architectural, engineer-
ing, surveying, soil testing, reimburse-
ment bond issuance, and similar costs
that are incurred prior to commence-
ment of acquisition, construction, or
rehabilitation of a project, other than
land acquisition, site preparation, and
similar costs incident to commence-
ment of construction.
(g) Special rules on refundings—(1) In
general—once financed, not reimbursed.
Except as provided in paragraph (g)(2)
of this section, paragraph (d) of this
section does not apply to an allocation
to pay principal or interest on an obli-
gation or to reimburse an original ex-
penditure paid by another obligation.
Instead, such an allocation is analyzed
under rules on refunding issues. See
§1.148–9.
(2) Certain proceeds of prior issue used
for reimbursement treated as unspent. In
the case of a refunding issue (or series
of refunding issues), proceeds of a prior
issue purportedly used to reimburse
original expenditures are treated as
unspent proceeds of the prior issue un-
less the purported reimbursement was
a valid expenditure under applicable
law on reimbursement expenditures on
the issue date of the prior issue.
(h) Anti-abuse rules—(1) General rule.
A reimbursement allocation is not an
expenditure of proceeds of an issue
under this section if the allocation em-
ploys an abusive arbitrage device under
§1.148–10 to avoid the arbitrage restric-
tions or to avoid the restrictions under
sections 142 through 147.
(2) One-year step transaction rule—(i)
Creation of replacement proceeds. A pur-
ported reimbursement allocation is in-
valid and thus is not an expenditure of
proceeds of an issue if, within 1 year
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26 CFR Ch. I (4–1–20 Edition) §1.150–4
after the allocation, funds cor-
responding to the proceeds of a reim-
bursement bond for which a reimburse-
ment allocation was made are used in a
manner that results in the creation of
replacement proceeds (as defined in
§1.148–1) of that issue or another issue.
The preceding sentence does not apply
to amounts deposited in a bona fide
debt service fund (as defined in §1.148–
1).
(ii) Example. The provisions of para-
graph (h)(2)(i) of this section are illus-
trated by the following example.
Example. On January 1, 1994, County A
issues an issue of 7 percent tax-exempt bonds
(the 1994 issue) and makes a purported reim-
bursement allocation to reimburse an origi-
nal expenditure for specified capital im-
provements. A immediately deposits funds
corresponding to the proceeds subject to the
reimbursement allocation in an escrow fund
to provide for payment of principal and in-
terest on its outstanding 1991 issue of 9 per-
cent tax-exempt bonds (the prior issue). The
use of amounts corresponding to the pro-
ceeds of the reimbursement bonds to create a
sinking fund for another issue within 1 year
after the purported reimbursement alloca-
tion invalidates the reimbursement alloca-
tion. The proceeds retain their character as
unspent proceeds of the 7 percent issue upon
deposit in the escrow fund. Accordingly, the
proceeds are subject to the 7 percent yield
restriction of the 1994 issue instead of the 9
percent yield restriction of the prior issue.
(i) Authority of the Commissioner to
prescribe rules. The Commissioner may
by revenue ruling or revenue procedure
(see §601.601(d)(2)(ii)(b) of this chapter)
prescribe rules for the expenditure of
proceeds of reimbursement bonds in
circumstances that do not otherwise
satisfy this section.
(j) Effective date—(1) In general. Ex-
cept as otherwise provided, the provi-
sions of this section apply to all alloca-
tions of proceeds of reimbursement
bonds issued after June 30, 1993.
(2) Transitional rules—(i) Official in-
tent. An official intent is treated as
satisfying the official intent require-
ment of paragraph (d)(1) of this section
if it—
(A) Satisfied the applicable provi-
sions of §1.103–8(a)(5) as in effect prior
to July 1, 1993, (as contained in 26 CFR
part 1 revised as of April 1, 1993) and
was made prior to that date, or
(B) Satisfied the applicable provi-
sions of §1.103–18 as in effect between
January 27, 1992, and June 30, 1993, (as
contained in 26 CFR part 1 revised as of
April 1, 1993) and was made during that
period.
(ii) Certain expenditures of private ac-
tivity bonds. For any expenditure that
was originally paid prior to August 15,
1993, and that would have qualified for
expenditure by reimbursement from
the proceeds of a private activity bond
under T.D. 7199, section 1.103–8(a)(5),
1972–2 C.B. 45 (see §601.601(d)(2)(ii)(b)) of
this chapter, the requirements of that
section may be applied in lieu of this
section.
(3) Nature of expenditure. Paragraph
(d)(3) of this section applies to bonds
that are sold on or after October 17,
2016.
[T.D. 8476, 58 FR 33551, June 18, 1993; 58 FR
44453, Aug. 23, 1993; T.D. 9777, 81 FR 46598,
July 18, 2016]
§1.150–4 Change in use of facilities fi-
nanced with tax-exempt private ac-
tivity bonds.
(a) Scope. This section applies for
purposes of the rules for change of use
of facilities financed with private ac-
tivity bonds under sections 150(b)(3)
(relating to qualified 501(c)(3) bonds),
150(b)(4) (relating to certain exempt fa-
cility bonds and small issue bonds),
150(b)(5) (relating to facilities required
to be owned by governmental units or
501(c)(3) organizations), and 150(c).
(b) Effect of remedial actions—(1) In
general. Except as provided in this sec-
tion, the change of use provisions of
sections 150(b) (3) through (5), and
150(c) apply even if the issuer takes a
remedial action described in §§1.142–2,
1.144–2, or 1.145–2.
(2) Exceptions—(i) Redemption. If non-
qualified bonds are redeemed within 90
days of a deliberate action under
§1.145–2(a) or within 90 days of the date
on which a failure to properly use pro-
ceeds occurs under §1.142–2 or §1.144–2,
sections 150(b) (3) through (5) do not
apply during the period between that
date and the date on which the non-
qualified bonds are redeemed.
(ii) Alternative qualifying use of facil-
ity. If a bond-financed facility is used
for an alternative qualifying use under
§§1.145–2 and 1.141–12(f), sections 150(b)
(3) and (5) do not apply because of the
alternative use.
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