Arbitrage Rebate
Compliance.

Tax-exempt bond proceeds come with IRS arbitrage rules. We track spend-down, monitor potential rebate liability and coordinate the calculations and filings — to help you anticipate rebate obligations before a computation is due.

Benefits.
  • Provides quarterly updates on potential arbitrage payments
  • Calculates arbitrage spend-down status
  • Provides interest earnings projections
  • Coordinates formal calculation for presentation to IRS, if necessary
  • Assists with IRS Forms 8038-T and 8038-R
  • Supports compliance with policies, federal and state statutes
  • Records ready for auditors and bond counsel
  • Coordinated with your bond proceeds strategy
Our process

Monitor early.
File on schedule.

Arbitrage compliance starts at closing, not at the deadline. We monitor from day one and coordinate the formal work when it’s needed.

01

Ongoing Monitoring

  • Spend-down schedules built at closing
  • Tracking against spend-down exceptions
  • Three-year temporary period tracking
  • Quarterly updates on potential rebate liability
  • Investment earnings compared to bond yield
02

Calculation & Filing

  • Coordination of formal rebate calculations
  • IRS Form 8038-T — arbitrage rebate payments
  • IRS Form 8038-R — recovery of overpayments
  • Documentation for auditors and bond counsel
  • Guidance through final maturity or redemption

Ampersand Public Advisors does not provide tax or legal advice; IRS filings are coordinated with your bond counsel or tax advisor.

Spend-down exceptions

Know where you stand
every quarter.

Meeting a spend-down exception may exempt an issue from rebate requirements (yield restriction rules may still apply). We track your progress against each one.

01

6-month exception

Proceeds spent within six months of issuance.

02

18-month exception

Proceeds spent on a set schedule over eighteen months.

03

2-year exception

For construction issues spent on schedule over two years.

Arbitrage Compliance Consultation

Unsure of your rebate exposure?
Let’s take a look.

We’ll review your outstanding issues and show you where each stands against spend-down and rebate requirements.