Public Finance Advisory: Treasury Proposes Circular 230 Regulations Affecting Bond Counsel Opinions
12/21/2004
On December 17, 2004, the United States Treasury Department and the Internal Revenue Service issued proposed "Circular 230" regulations relating to standards of practice for bond counsel opinions ("bond opinions"). The proposed regulations were issued simultaneously with final ?Circular 230" regulations affecting tax shelter opinions. The final regulations carve out bond opinions from the specific requirements applicable to tax shelter opinions, and the proposed regulations substitute separate requirements specifically applicable only to bond opinions.
The attached publication discusses the requirements of the proposed regulations and the implications of those regulations for the bond market.
