The following definitions apply:
BOND means any obligation of a State or political subdivision thereof under section 103(c)(1).
BOND DOCUMENTS means the bond indenture or resolution, transcript of proceedings, and any related documents.
CAPITAL EXPENDITURE means any cost of a type that is properly chargeable to capital account (or would be so chargeable with a proper election or with the application of the definition of placed in service under section 1.150-2(c)) under general Federal income tax principles. For example, costs incurred to acquire, construct, or improve land, buildings, and equipment generally are capital expenditures. Whether an expenditure is a capital expenditure is determined at the time the expenditure is paid with respect to the property. Future changes in law do not affect whether an expenditure is a capital expenditure.
CONDUIT BORROWER means the obligor on a purpose investment (as defined in section 1.148-1). For example, if an issuer invests proceeds in a purpose investment in the form of a loan, lease, installment sale obligation, or similar obligation to another entity and the obligor uses the proceeds to carry out the governmental purpose of the issue, the obligor is a conduit borrower.
CONDUIT FINANCING ISSUE means an issue the proceeds of which are used or are reasonably expected to be used to finance at least one purpose investment representing at least one conduit loan to one conduit borrower.
CONDUIT LOAN means a purpose investment (as defined in section 1.148-1).
GOVERNMENTAL BOND means any bond of an issue of tax-exempt bonds in which none of the bonds are private activity bonds.
ISSUANCE COSTS means costs to the extent incurred in connection with, and allocable to, the issuance of an issue within the meaning of section 147(g). For example, issuance costs include the following costs but only to the extent incurred in connection with, and allocable to, the borrowing: underwriters‘ spread; counsel fees; financial advisory fees; rating agency fees; trustee fees; paying agent fees; bond registrar, certification, and authentication fees; accounting fees; printing costs for bonds and offering documents; public approval process costs; engineering and feasibility study costs; guarantee fees, other than for qualified guarantees (as defined in section 1.148-4(f)); and similar costs.
ISSUE DATE means, in reference to an issue, the first date on which the issuer receives the purchase price in exchange for delivery of the evidence of indebtedness representing any bond included in the issue. Issue date means, in reference to a bond, the date on which the issuer receives the purchase price in exchange for that bond. In no event is the issue date earlier than the first day on which interest begins to accrue on the bond or bonds for Federal income tax purposes.
OBLIGATION means any valid evidence of indebtedness under general Federal income tax principles.
POOLED FINANCING ISSUE means an issue the proceeds of which are to be used to finance purpose investments representing conduit loans to two or more conduit borrowers, unless those conduit loans are to be used to finance a single capital project.
PRIVATE ACTIVITY BOND means a private activity bond (as defined in section 141).
QUALIFIED MORTGAGE LOAN means a mortgage loan with respect to an owner-occupied residence acquired with the proceeds of an obligation described in section 143(a)(1) or 143(b) (or applicable prior law).
QUALIFIED STUDENT LOAN means a student loan acquired with the proceeds of an obligation described in section 144(b)(1).
RELATED PARTY means, in reference to a governmental unit or a 501(c)(3) organization, any member of the same controlled group, and, in reference to any person that is not a governmental unit or 501(c)(3) organization, a related person (as defined in section 144(a)(3)).
TAXABLE BOND means any obligation the interest on which is not excludable from gross income under section 103.
TAX-EXEMPT BOND means any bond the interest on which is excludable from gross income under section 103(a). For purposes of section 148, tax-exempt bond includes:
(1) An interest in a regulated investment company to the extent that at least 95 percent of the income to the holder of the interest is interest that is excludable from gross income under section 103; and
(2) A certificate of indebtedness issued by the United States Treasury pursuant to the Demand Deposit State and Local Government Series program described in 31 CFR part 344.
WORKING CAPITAL EXPENDITURE means any cost that is not a capital expenditure. Generally, current operating expenses are working capital expenditures.