Internal Revenue Service
CC:PA:LPD:PR (REG-129067-15)
PO Box 7604
Ben Franklin Station
Washington, DC 20044
May 23, 2016
RE:
REG-129067-15, Proposed Rulemaking – Definition of Political Subdivision
Dear Commissioner:
[AUTHORITY, AGENCY, POLITICAL SUBDIVISION NAME HERE] writes today to associate ourselves with
comments filed by the Government Finance Officers Association (GFOA) in relation to the Proposed
Regulations regarding the definition of political subdivision for purposes of tax-exempt bonds issued by
the Internal Revenue Service (IRS) on February 23, 2016.
[AUTHORITY, AGENCY, POLITICAL SUBDIVISION NAME HERE] agrees with GFOA that the Proposed
Regulations would add extensive and additional federal requirements on entities established by the
State to serve a purpose that is in the best interest of the State.
Special districts in the U.S. encompass a wide variety of public purposes and to help fulfill their purpose,
they have the ability to issue tax-exempt debt. The Proposed Regulations impact not only the ability to
issue future tax-exempt bonds that would consequently weaken our country’s aging infrastructure, but
also impact outstanding bonds issued by political subdivisions. The Proposed Regulations would hinder
the ability of the political subdivisions to effectively, efficiently and economically serve communities. We
respectfully as that the Proposed Regulations be withdrawn.
Sincerely,
[NAME]
[TITLE]
[AUTHORITY, AGENCY, POLITICAL SUBDIVISION NAME HERE]