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TEB - Bond Redemption

Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States

TEB may require as a prerequisite to entering into a closing agreement that the issuer redeem, retire or defease callable bonds of the issue at the earliest possible date.

For exam closing agreements, if the issuer can’t redeem, retire or purchase and cancel the callable bonds before the closing agreement execution date, the closing agreement must:

Specify the date on which the bonds will be redeemed.

Require the issuer to call the bonds for redemption on that date.

Require the issuer to provide the bondholders with an irrevocable call notice. The irrevocable call notice must include the specific date on which the issuer has stated that the redemption will occur. The issuer must provide TEB with documentation of this call notice prior to TEB executing the closing agreement.

Require the issuer to establish, prior to TEB executing the closing agreement, a fully funded irrevocable defeasance escrow or similar escrow satisfactory to TEB to provide for the payment of the principal and interest on the bonds to the call date. The issuer must provide TEB with documentation that it has established the irrevocable defeasance escrow prior to TEB executing the closing agreement.

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