SECTION 6. Special Rules
Internal Revenue Bulletin 2008-15 · 2026-10-03 edition · updated 2026-10-04 · United States
6.1. Special Rule for Nonrecourse Debt . Solely for purposes of § 103 and §§ 141 through 150, in applying § 1.1001–3(e)(4)(iv)(B) to determine whether a modification of the security or credit enhancement on a tax-exempt bond that is a nonrecourse debt instrument is a significant modification, such a modification is treated as a significant modification only if the modification results in a change in payment expectations under § 1.1001–3(e)(4)(vi).
6.2. Special Temporary Relief for Cer- tain Waivers of Interest Rate Caps on Auc- tion Rate Bonds . Solely for purposes of § 103 and §§ 141 through 150, in applying § 1.1001–3(e)(2) to determine whether a modification to the yield on tax-exempt bonds that bear interest based on an auction rate constitutes a significant modification, a temporary waiver, in whole or in part, of the terms of a cap on the maximum interest rate on such auction rate bonds is disregarded to the extent that any agreement to waive such a cap and the period during which such a waiver is in effect both are within the period between November 1, 2007 and October 1, 2008. Except for the special relief provided in this section, a waiver of a cap on an interest rate on a tax-exempt bond generally is required to be tested for whether it causes a significant modification under § 1.1001–3.
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