SECTION 6. ARBITRAGE

REQUIREMENTS FOR GULF TAX CREDIT BONDS

Section 1400N(l)(4)(D) generally provides that the arbitrage requirements of § 148 applicable to tax-exempt State or local bonds apply to Gulf Tax Credit Bonds and any loans made with the proceeds of such bonds. In applying § 148 to Gulf Tax Credit Bonds the following special rules apply—

2006–18 I.R.B. 859 May 1, 2006

arately computed with respect to such person’s interest in such entity) equal to the amount of tax attributable to that portion of the person’s taxable income in such year that is allocable or apportionable to the person’s interest in such entity.