Public

(ii) Public means any person (as defined in section 7701(a)(1)) other than an underwriter or a related party (as defined in 1.150-1(b)) to an underwriter. (iii) Underwriter means: (A) Any person (as defined in section 7701(a)(1)) that agrees pursuant to a written contract with the issuer (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the bonds to the public; and (B) Any person that agrees pursuant to a written contract directly or indirectly with a person described in paragraph (f)(3)(iii)(A) of this section to participate in the initial sale of the bonds to the public (for example, a retail distribution agreement between a national lead underwriter and a regional firm under which the regional firm participates in the initial sale of the bonds to the public). (4) Other special rules. For purposes of this paragraph (f), the following special rules apply: (i) Separate determinations. The issue price of bonds in an issue that do not have the same credit and payment terms is determined separately. The issuer need not apply the same rule to determine issue price for all of the bonds in the issue. (ii) Substantial amount. Ten percent is a substantial amount. (iii) Bonds issued for property. If a bond is issued for property, the adjusted applicable Federal rate, as determined under section 1288 and 1.1288-1, is used in lieu of the applicable Federal rate to determine the bond's issue price under section 1274.

Source

26 CFR § 1.148-1


Scoping language

None
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