A Note from the Editors-in-Chief

In their article, the authors describe tax-exempt municipal debt securitization transactions and the tax issues associated with these transactions, including (1) whether the securitization vehicle is transparent from a federal income tax perspective and (2) whether the certificates representing owne...

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Bibliographic Details
Published in:Journal of Taxation of Financial Products 2021-09, Vol.18 (3), p.3-4
Main Authors: Price, Mark H, Tompkins, Joshua S
Format: Article
Language:English
Subjects:
Accounting firms
Brokers
Crypto-currencies
Digital currencies
Executives
Financial institutions
Financial markets
Income taxes
Infrastructure
Non-fungible tokens
Provisions
Securitization
Tax services
Vehicles
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Summary:In their article, the authors describe tax-exempt municipal debt securitization transactions and the tax issues associated with these transactions, including (1) whether the securitization vehicle is transparent from a federal income tax perspective and (2) whether the certificates representing ownership in the securitization vehicle will be respected as equity for tax purposes. The article continues with discussions, in the context of securitization vehicles that are treated as partnerships for federal income tax purposes, of (1) concerns that arise from hedging the risks of ownership of certain equity interests with total return swaps and (2) an elective, simplified federal income tax information reporting regime. [...]the article ends with a short discussion of state and local tax issues with respect to the securitization of the taxexempt municipal debt.
ISSN:1529-9287