Notice 2024-32, page 897.

This notice provides guidance for qualified student loan bonds to clarify certain requirements for tax-exempt bond financing for loan programs of general application approved by a State under § 144(b)(1)(B) (State Supplemental Loan programs). Specifically, this notice addresses eligibility of borrowers of loans through State Supplemental Loan programs and the loan size limitation for State Supplemental Loans. This notice also provides guidance on whether an issue of State or local bonds the proceeds of which are used to finance or refinance qualified student loans or to finance qualified mortgage loans is a refunding issue.

REG-108761-22, page 933. This Notice of Proposed Rulemaking (NPRM) would add a new regulation section promulgated under section 6011 of the Code to establish that Charitable Remainder Annuity Trust (CRAT) transactions described in the NPRM are listed transactions for purposes of Treasury Regulation § 1.6011-4 and sections 6111 and 6112. The transaction at issue is one in which taxpayers purport to eliminate recognition of ordinary income and/or capital gain on appreciated property contributed to a CRAT when the CRAT sells that property and purchases a single premium immediate annuity (SPIA). Taxpayers misapply the rules governing CRAT’s upon the sale of the appreciated property by the CRAT and also misapply the rules concerning the SPIA by treating the beneficiaries as the owners of the SPIA, rather than it being an asset of the CRAT funding the annuity payments from the trust.