63-20 Financing

In Revenue Ruling 63-20 the IRS ruled that, in certain circumstances, bonds issued by a nonprofit corporation (the “Nonprofit”) will be considered issued on behalf of a Governmental Unit – thus allowing the interest on such bonds to be eligible for tax-exempt treatment. A 63-20 financing may help avoid certain political and legal hurdles that otherwise might be present if the Governmental Unit were to issue the bonds directly.