TEB - Negotiating and Drafting of Closing Agreements
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
Issuers may:
Request a closing agreement with the IRS to preserve the tax-advantaged status of their bonds.
Be joined by other parties to a tax-advantaged bond transaction in entering into a closing agreement.
TEB enters into closing agreements with the issuer of the bond issue.
In certain exam cases, other parties to the bond transaction may also participate in the negotiations and jointly execute the agreement.
The issuer must complete a Form 8821, Tax Information Authorization, to allow parties who have not been designated as a representative under Form 2848, Power of Attorney and Declaration of Representative, to participate in the negotiations.
The conduit borrower or other party may designate its own representative under Form 2848.
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