IRS Intellectual Property and Private Activity
John Dickinson (907) 474-7448 03 Apr 1997 12:40 EST
Federal register publication of final rules (draft were published 12/94) was at
page 2275 on January 16, 1997. Research contracts follows the section on
management contracts (food service etc.. Rules apply to all bonds issued on or
after May 16, 1997, and can be used as "safe harbor" for earlier bonds, so long
as you use all of the new rules for all of the old bonds.
Revenue procedure 97-14 states that "private activity" use is measured over
term of issue rather than on an annual basis.
Yesterday I said the private activity use was limited to 5%/10%. If your
university issues state bonds (you are state government as opposed to a
501(c)(3) corporation authorized by the state), you get to use the 10%, all of
which can be for-profit.
John Dickinson
Assistant to the VP for Finance
University of Alaska
910 Yukon Drive, Suite 207
PO Box 73147
Fairbanks, AK 99775-5120
phone: (907) 474-5012
fax: (907) 474-5140
e-mail: xxxxxx@orca.alaska.edu