TEB - Computing Value as of the Closing Agreement Execution Date

Value as of the approximate date that TEB receives any payment required per the closing agreement terms (the "agreement execution date" ) including:

Past or future tax liabilities or payments.

Past or future excessive arbitrage profit.

To value a past payment, liability or benefit, future value that amount to the agreement execution date using both the applicable underpayment rate(s) under IRC 6621 as the discount rate and a daily compounding method per IRC 6622.

To value any amount representing a future payment, liability or benefit:

Present value that amount to the agreement execution date.

Use, as the discount rate, the appropriate short-term, mid-term, or long-term semi-annual compounding applicable federal rate (AFR) in effect on the agreement execution date and for the term from the agreement execution date to the assumed April 15 tax payment date corresponding to that future tax year (with respect to tax-exempt bonds), the future credit allowance date (with respect to tax credit bonds) or the future interest payment date (with respect to direct pay bonds), as applicable, in accordance with the terms provided in IRC 1274(D)(1).

Treat any tax year that has an assumed April 15 tax payment date or interest payment date later than the agreement execution date as a future tax year payment.