Tax-Exempt Bonds, 2008

Tax-Exempt Bonds, 2008

by Aaron Barnes

S

tate and local governments across the United

States and its territories issue tax-exempt bonds

to finance essential operations, facilities, infrastructure, and services for their constituents.1 Taxexempt bonds issued by State and local governments

are classified as either “governmental” or “private

activity,” depending on whether the proceeds are

used and secured by public or private entities and

resources.

The total amount of tax-exempt bonds issued by

State and local governments decreased by 9.1 percent

between Calendar Years 2007 and 2008, from $516.7

billion in 2007 to $469.4 billion in 2008. For 2008,

governmental bonds accounted for $334.4 billion

(71.2 percent) of total tax-exempt bond proceeds.

Private activity bonds accounted for the remaining

$135.0 billion (28.8 percent).

When a bond is issued, the issuer is obligated to

repay the borrowed bond proceeds, at a specified rate

of interest, by some future date. For Federal income

tax purposes, investors who purchase governmental

bonds and certain types of private activity bonds are

able to exclude the bond interest from their gross

incomes.2 This tax exemption lowers the borrowing cost incurred by tax-exempt bond issuers, since

holders of tax-exempt bonds are generally willing

to accept an interest rate lower than that earned on

comparable taxable bonds. The interest exclusion for

tax-exempt bonds is not allowed for arbitrage bonds

and bonds not in registered form.3, 4

Aaron Barnes is an economist with the Special Studies

Special Projects Section. This data release was prepared

under the direction of Melissa Ludlum, Chief.

Both governmental and private activity bonds

are obligations issued by or on behalf of State and

local governmental units; the use of the proceeds

differentiates the two. Governmental bond proceeds

finance essential government operations, facilities,

and services that are for general public use, and the

debt service on these bonds is paid from general governmental sources. Private activity bonds are issued

by or on behalf of State or local governments for the

purpose of financing the project of a private user.

Since private activity bond proceeds are used by one

or more private entities, the debt service is paid or

secured by one or more private entities. Specifically,

section 141(a) of the Internal Revenue Code (IRC)

provides that the term private activity bond means

any bond issued as part of an issue which meets: 1)

the private business tests set forth in the IRC section 141(b); or 2) the private loan financing test set

forth in IRC section 141(c).5 Interest income earned

on most private activity bonds is taxable. However,

over the years, Congress has deemed certain types

of private activities necessary for the public good,

and, therefore, interest income earned on “qualified

private activity bonds,” as defined in IRC section

141(e), is generally tax-exempt.6, 7

The data presented in this data release are

based on the populations of Forms 8038, Information Return for Tax-Exempt Private Activity Bond

Issues, and Forms 8038-G, Information Return for

Tax-Exempt Governmental Obligations, filed with

the Internal Revenue Service for bonds issued during Calendar Year 2008. The vast majority of these

returns were filed in 2008 and 2009 for tax-exempt

1

The term “State” includes the District of Columbia and any possessions of the United States.

In addition, for State income tax purposes, most States allow for the exclusion of interest on bonds issued by government agencies within their own States, thus increasing

the benefit to the bondholder.

3 An arbitrage bond is one in which any portion of the proceeds is used to purchase higher-yielding investments, or is used to replace proceeds which have been used to

purchase higher-yielding investments. Certain rules allow for arbitrage earnings with respect to tax-exempt bonds within a specified time period, as long as these earnings

are rebated to the Department of the Treasury.

4 A registered bond is defi ned as: “a bond whose owner is designated on records maintained by a registrar, the ownership of which cannot be transferred without the registrar recording the transfer on its records.” (From the Municipal Securities Rulemaking Board’s Glossary of Municipal Securities Terms http://www.msrb.org/msrbl/glossary.

See also IRC section 149(a) for additional information).

5 The private business tests of IRC section 141(b) defi ne a bond as a private activity bond if both of the following criteria are met: 1) more than 10 percent of the bond

proceeds are used for a private business purpose; and, 2) more than 10 percent of the bond debt service is derived from private business use and is secured by privately used

property. The private loan fi nancing test of IRC section 141(c) defi nes a bond as a private activity bond if the amount of the proceeds used to (directly or indirectly) fi nance

loans to nongovernmental persons exceeds the lesser of $5 million or 5 percent of the proceeds.

6 Tax-exempt private activity bonds include “exempt facility bonds,” qualified mortgage bonds, qualified veterans’ mortgage bonds, qualified small issue bonds, qualified

student loan bonds, qualified redevelopment bonds, and qualified section 501(c)(3) bonds (all of which are defi ned in the “Explanation of Terms” section of this article).

Examples of exempt facilities include airports; docks and wharves; sewage facilities; solid waste disposal facilities; qualified residential rental projects; and facilities for the

local furnishing of electricity or gas. Qualified section 501(c)(3) bonds are issued by State and local governments to fi nance the activities of charitable and similar organizations that are tax-exempt under IRC section 501(c)(3). The primary beneficiaries of these bonds are hospitals, universities, and organizations that provide low-income

housing or assisted-living facilities.

7 The interest income from qualified private activity bonds (other than qualified section 501(c)(3) bonds) is considered a tax preference for the alternative minimum tax

calculations.

2

125

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Tax Credit Bonds

T

ax credit bonds differ from tax-exempt bonds

in that they are not explicitly interest-bearing

obligations. In lieu of receiving periodic

interest payments from the issuer, a bondholder

is generally allowed an annual income tax credit

while the bond is outstanding. The amount of the

credit is determined by multiplying the bond’s

credit rate by the face amount on the holder’s

bond. The credit rate on the bonds is determined

by the Secretary of the Treasury and is an estimate of the rate that permits issuance of such

bonds without discount and interest cost to the

qualified issuer. The credit is includable in the

bondholder’s gross income (as if it were an interest payment on the bond), and it can be claimed

against regular income tax liability and alternative

minimum tax liability.

The Taxpayer Relief Act of 1997 created the

first type of tax credit bond—the qualified zone

academy bond. In 2005, two additional types—

clean renewable energy bonds and Gulf tax credit

bonds—were created. Since then, various legislation has authorized additional types of tax credit

bonds, such as qualified forestry conservation

bonds, new clean renewable energy bonds, qualified energy conservation bonds, Midwestern tax

credit bonds, and qualified school construction

bonds.1, 2 Issuers of tax credit bonds are required

to submit to the IRS information filings similar to

those required of tax-exempt bonds issuers.

In 2008, State and local governments issued

$253 million in tax credit bonds.3 This amount included $248 million in new money long-term tax

Total Tax-Exempt and Tax Credit Bonds, 2008

[Money amounts are in millions of dollars]

Type of bond

Number

Total[1]

Tax-exempt bonds

Tax credit bonds [2]

Amount

27,833

469,610

27,730

103

469,357

253

[1] Includes combined data from all government and private activity bond returns

(Forms 8038-G, Information Return for Tax-Exempt Governmental Obligations Bonds

and Forms 8038, Information Return for Tax-Exempt Private Activity Bond Issues ).

Data contains information for new money and refunding issues, as well as short-term

and long term issues.

[2] Includes data from governmental and private activity bond returns (Forms 8038-G

and Forms 8038) that specifically reference "qualified zone academy" bonds or "clean

renewable energy" bonds.

NOTE: Detail may not add to totals because of rounding.

New Money Long-Term Tax Credit Bonds, by Bond Purpose and Size of

Entire Issue, 2008

[Money amounts are in millions of dollars, except for size of entire issue, which is in whole dollars]

Size of entire issue

Bond purpose

All issues

$1,000,000

under

$5,000,000

Under

$1,000,000 [1]

$5,000,000

or

more

Number Amount Number Amount Number Amount Number Amount

(1)

Total, tax credit bonds [2]

(2)

(3)

(4)

(5)

(6)

(7)

(8)

99

248

36

17

49

94

14

Qualified zone academy bonds [3]

71

143

29

13

33

60

9

136

70

Clean renewable energy bonds [3]

28

105

7

4

16

34

5

66

[1] Forms 8038-G with an entire issue price less than $100,000 are excluded from the study. Issuers of these bonds are instructed to file Forms 8038-GC,

Information Return for Small Tax-Exempt Governmental Bond Issues, Leases, and Installment Sales. Statistics of Income (SOI) does not process data from

Forms 8038-GC filed with the Internal Revenue Service.

[2] Includes combined data from all governmental and private activity bond returns (Forms 8038-G and Forms 8038).

[3] Includes data from governmental and private activity bond returns (Forms 8038-G and Forms 8038) that specifically reference "qualified zone academy"

bonds or "clean renewable energy" bonds.

NOTE: Detail may not add to totals because of rounding.

credit bonds, of which $143 million were qualified

zone academy bonds, and $105 million were clean

renewable energy bonds.

For 2008, new money long-term tax credit bonds

had the following distribution by entire issue size:

36.4 percent of all tax credit bond issues were under

$1 million, almost 50.0 percent were in the $1 million

to $5 million range, and 14.1 percent were in excess

1 The Food, Conservation, and Energy Act of 2008 created qualified forestry conservation bonds. The Energy Improvement and Extension Act of 2008 produced new clean renewable energy bonds and qualified energy conservation bonds. The Tax Extenders and Alternative Minimum Tax Relief Act of 2008 created

Midwestern tax credit bonds.

2 Different categories of tax credit bonds vary in terms of the allowable tax credit rate, maturity, and other features. For example, clean renewable energy bonds and

qualified zone academy bonds have a 100-percent tax credit subsidy; however, new clean renewable energy bonds and qualified energy conservation bonds have a

70-percent subsidy. Borrowers are likely to issue at a discount or pay taxable interest in addition to the lender receiving a tax credit.

3 Issue Year 2008 data do not include direct payment bonds, such as build America bonds or recovery zone economic development bonds created by the American

Recovery and Reinvestment Act of 2009. Additionally, the 2008 data do not contain any data with regard to direct payment tax credit bonds (i.e., qualified forestry

conservation bonds, new clean renewable energy bonds, qualified energy conservation bonds, and qualified school construction bonds authorized by the Hiring

Incentives to Restore Employment Act of 2010).

126

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Tax Credit Bonds—Continued

of $5 million. However, more than half ($136

million) of the total $248 million in tax credit

bond proceeds were from bonds with an entire issue size greater than $5 million.

The five States with the highest dollar issuance of tax credit bonds were California, Florida,

Mississippi, Connecticut, and North Carolina.

Combined, these States issued $89 million, or 35.9

percent of all new money long-term tax credit

bonds. Florida issued the largest amount of qualified zone academy bonds, accounting for 14.7

percent ($21 million) of the total. California issued $32 million in clean renewable energy bonds,

nearly 30.5 percent of the total, making it the largest issuer of clean renewable energy bonds.

bonds.8 However, for 2008, the issuers of tax-credit

bonds were also required to use these forms to report

certain information to the IRS. For this reason, the

article also includes a separate discussion of taxcredit bonds.

Bond Volume, by Term of Issue

Bonds are classified as either short-term or longterm, depending on the length of time from issuance

to maturity. Bonds having maturities of less than

13 months are typically classified as short-term,

while those having maturities of 13 months or more

are classified as long-term. Governmental bond issues totaled $334.4 billion in 2008, an 11.8-percent

decrease from the $379.3 billion issued in 2007.

Long-term bonds accounted for $271.7 billion, more

than 81.2 percent of all governmental bond proceeds.

Long-term bonds are generally used to finance construction or other capital improvement projects.

The remaining $62.7 billion of governmental

bonds were issued for short-term projects. Most

short-term governmental bonds are issued in the

form of tax anticipation notes (TANs), revenue an-

New Money Long-Term Tax Credit Bonds, by State of Issue and Bond Purpose,

2008

[Money amounts are in millions of dollars]

State

Total tax credit bonds

[1]

Number

Amount

(1)

Total, All States

Arkansas

California

Connecticut

Florida

Iowa

Maine

Minnesota

Mississippi

Missouri

North Carolina

Oklahoma

South Dakota

West Virginia

Wisconsin

All other States, combined

Qualified zone

academy bonds [2]

Number

Amount

(2)

(3)

Clean renewable

energy bonds [2]

Number Amount

(4)

(5)

(6)

99

248

71

143

28

4

1

4

1

0

0

12

39

4

7

8

105

32

3

9

d

d

d

d

3

21

3

21

0

0

3

6

d

d

d

d

4

2

4

2

0

0

3

5

d

d

d

d

6

12

6

12

0

0

3

4

d

d

d

d

5

8

5

8

0

0

7

4

7

4

0

0

4

1

4

1

0

0

5

4

5

4

0

4

4

4

4

33

128

18

66

d- Data deleted to avoid disclosure of information for specific bonds when compared to other published data.

0

0

0

15

63

[1] Includes combined data from all governmental and private activity bond returns (Forms 8038-G and Forms 8038).

[2] Includes data from governmental and private activity bond returns (Forms 8038-G and Forms 8038) that specifically reference

"qualified zone academy" bonds or "clean renewable energy" bonds.

NOTE: Detail may not add to totals because of rounding.

ticipation notes (RANs), or bond anticipation notes

(BANs). TANs and RANs generally mature within 1

year of issuance, at which time the proceeds are paid

from specific tax receipts or other revenue sources.

The proceeds of a BAN are typically used to pay

for startup costs associated with a future, long-term

bond-financed project. A renewal BAN can be issued

on maturity of an outstanding BAN, until, eventually, the proceeds of the future bond issue are used to

pay off, or retire, the outstanding BAN. Combined,

TANs, RANs, and BANs comprised 91.5 percent of

all short-term governmental bond proceeds for 2008.

Tax-exempt private activity bond issues totaled

$135.0 billion in 2008, a 1.7-percent decrease from

the $137.4 billion issued in 2007. Short-term bonds

accounted for almost $2.2 billion, only 1.6 percent,

of the total private activity bond proceeds for 2008.

Long-Term Bond Volume, by Type of Issue

Total bond issuance is composed of both (“new

money”) nonrefunding issues and refunding issues.

The proceeds of new money issues finance new capital projects, while proceeds of refunding issues retire

8

Bond issuers were required to file these tax-exempt bond information returns by the 15th day of the second calendar month after the close of the calendar quarter in which

the bond was issued. The study includes returns processed from January 1, 2008, to May 2, 2010, for bonds issued in 2008.

127

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Figures B1 and B2 present the composition of longterm tax-exempt bond proceeds, by selected purpose,

as well as type of issue for both governmental and

private activity bond issues. During 2008, nearly

two-thirds (61.9 percent) of the total $271.7 billion

of long-term governmental bond proceeds financed

education, utilities, and transportation projects. A

little more than one-fourth (26.1 percent) of the longterm governmental bond proceeds were allocated for

“other bond purposes” (i.e., specific purpose(s) did

not apply to specific line items or were not separately

allocated by the issuer). For almost all of the governmental bond purposes shown in Figure B1, more

proceeds were spent financing new capital projects

than were used to refund prior bond issues with the

exception of “Utilities” and “Health and Hospitals.”

Qualified section 501(c)(3) bonds, which include

total qualified hospital bonds and qualified nonhospital bonds issued to benefit entities exempt from

income tax under IRC section 501(c)(3), combined,

accounted for 65.0 percent of the $132.8 billion of

long-term private activity bonds issued for 2008.

Private activity bonds issued to provide housing assistance in the form of qualified residential rental

projects, qualified mortgages, and qualified veterans’

mortgage bonds accounted for another 13.3 percent

of total proceeds.9

Figures A1

Figures A2

Long-Term Governmental Bonds Issued, by

Type and Issue Year, 2004-2008

Long-Term Private Activity Bonds Issued, by

Type and Issue Year, 2004-2008

outstanding debt of prior bond issues. A bond issue

can include both new and refunding proceeds.

Figures A1 and A2 show total long-term issuance, as well as the split between new money and

refunding proceeds, for both governmental and

tax-exempt private activity bonds issued between

2004 and 2008. In 2008, 56.6 percent of all longterm governmental bond proceeds were new money

issues. New money governmental bond proceeds

fell by 23.2 percent to $153.8 billion, while refunding proceeds grew by approximately 1.5 percent from $116.1 billion in 2007 to $117.9 billion

in 2008.

In 2008, 39.5 percent of all long-term private

activity bond proceeds were new money issues. Between 2007 and 2008, new money private activity

bond proceeds fell by 39.4 percent to $52.5 billion,

while refunding proceeds grew by 60.6 percent from

$50.0 billion in 2007 to $80.3 billion in 2008.

Long-Term Bond Volume, by Selected Purpose

Billions of dollars

Billions of dollars

160

350

$316.3

$311.3

300

$271.7

$272.2

$269.4

$136.6

140

120

$109.5

250

$132.8

$108.6

$93.1

100

$200.1

$86.6

$180.2

200

$157.7

$80.3

$153.8

$159.8

80

$63.3

150

$54.8

$151.6

100

60

$111.8

$116.1

$47.9

$117.9

$54.7

40

$92.1

$52.5

$50.0

$45.2

$45.3

50

20

0

2004

2005

2006

2007

Issue year

All issues

9

128

New money proceeds

2008

0

2004

2005

2006

2007

2008

Issue year

Refunding proceeds

All issues

New money proceeds

Refunding proceeds

This figure does not include the relatively small amount of proceeds issued for qualified veterans’ mortgage bonds and Gulf Opportunity Zone mortgage bonds, which are

excluded to avoid disclosure of information about specific bonds.

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Figure B1

Figure B2

Long-Term Tax-Exempt Governmental Bonds, by Selected Bond

Purpose and Type of Issue, 2008

Long-Term Tax-Exempt Private Activity Bonds, by Selected Bond

Purpose and Type of Issue, 2008

Billions of dollars

Billions of dollars

50

80

45

70

40

$27.7

35

60

$27.7

30

50

$35.9

$19.2

25

40

20

$27.7

$19.6

30

15

$50.3

$43 3

$43.3

20

10

$22.2

$20.7

10

$7.4

$8.5

0

Education

Other purposes

[1]

Utilities

Transportation

Environment

5

$4.3

$2.8

$2.8

$4.0

Health and

hospital

Public safety

$18.6

$18 6

$12.7

$5.6

$7.5

$5.1

$1.8

0

Qualified

hospital

Qualified

section

501(c)(3)

nonhospital

Qualified

mortgage

Refunding proceeds

$4.6

Qualified

residential

rental

$1.1

$2.8

$1.4

$2.6

Qualified

Water, sewage,

student loan and solid waste

disposal

Bond purpose

Bond purpose

New money proceeds

Airport

$2.5

New money proceeds

Refunding proceeds

[1]"Otherpurposes"refertoobligationsforwhichaspecificpurposeeitherdidnotapplyorwasnotclearlyindicatedontheForm8038ͲG.

Overview of Bond Issues, by State

Total new money long-term governmental bond

volume decreased $46.4 billion (23.2 percent) from

2007 to 2008. California experienced the largest

absolute decrease (48.5 percent) in new money longterm governmental bond issues, from slightly more

than $30.9 billion in 2007 to $15.9 billion in 2008.

States with significant decreases in new money longterm governmental bond issues from 2007 to 2008

included Ohio, whose issuance fell 58.1 percent,

from $8.6 billion in 2007 to $3.6 billion in 2008;

Georgia, whose issuance decreased by 33.4 percent,

from $7.2 billion in 2007 to $4.8 billion in 2008; and

North Carolina, whose issuance fell 30.3 percent,

from approximately $5.4 billion in 2007 to $3.8 billion in 2008. In all, 35 States reduced the amount of

new money long-term governmental bonds issued

from 2007 to 2008, by $53.6 billion.

New York experienced the largest absolute increase (24.0 percent) in new money long-term governmental bond issues, from slightly more than $12.3

billion in 2007 to $15.3 billion in 2008. Maryland

also experienced a significant increase (23.2 percent)

in new long-term governmental bond issues from

$3.2 billion in 2007 to $3.9 billion in 2008. In all, 17

10

States increased the amount of new money long-term

governmental bonds issued from 2007 to 2008, by

nearly $7.4 billion.

Figures C1and C2 present the amount of bonds

issued for the top 15 States, in terms of total dollar

volume of new money long-term tax-exempt bonds

issued for 2008, for both governmental and private

activity bond issuances. Combined, the top 15 States

accounted for 72.2 percent of the total $153.8 billion

of new money long-term governmental bond issues

for the year. About $69.2 billion (45.0 percent) of

the total were issued by authorities in the following five States: Texas (14.0 percent), California

(10.4 percent), New York (10.0 percent), Florida

(6.9 percent), and Illinois (3.8 percent). According

to 2008 Census estimates, together, these five States

accounted for almost 36.7 percent of the total U.S.

population.10

An examination of issuance by State reveals

some differences in the allocation of proceeds by

bond purpose. Overall, for 2008, 32.7 percent of

the $153.8 billion of new money long-term governmental bonds was issued for educational purposes.

However, of the total amount of new money longterm bonds issued in Texas, 50.8 percent was issued

The resident population estimates for July 1, 2008, were produced by the U.S. Bureau of the Census and are available at http://www.census.gov/popest/states/NST-ann-est.html.

129

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Figure C1

New Money Long-Term Governmental Bonds, by Selected Bond Purpose, for Top 15 States, Ranked by

Total Governmental Bond Issuance, 2008

[Money amounts are in millions of dollars]

Selected bond purpose

Total

Education

State of issue

Other purposes [1]

Utilities

Transportation

(1)

(2)

153,771

50,313

Texas

21,593

10,962

(4)

32.7 43,281

50.8 3,022

California

15,918

5,510

34.6

5,331

33.5

1,098

6.9

New York

15,310

4,392

28.7

5,492

35.9

3,012

Florida

10,594

2,725

25.7

4,455

42.1

732

Illinois

5,770

1,847

32.0

1,240

21.5

Arizona

5,688

1,755

30.9

1,285

22.6

Pennsylvania

5,171

1,933

37.4

958

Total, All States

(3)

(5)

(6)

28.1 22,208

14.0 3,656

(7)

Environment

Percent of

State total

Percent of

Percent of

Percent of

Amount Amount

Amount

Amount

Amount

State total

State total

State total

(8)

14.4 20,722

16.9 2,882

Amount

Percent of

State total

(10)

(11)

(9)

13.5

8,509

5.5

13.3

215

1.0

2,706

17.0

546

3.4

19.7

993

6.5

204

1.3

6.9

1,765

16.7

666

6.3

1,659

28.8

603

10.5

252

4.4

858

15.1

833

14.6

d

d

18.5

1,291

25.0

51

1.0

585

11.3

16.6

Georgia

4,813

1,282

26.6

689

14.3

791

16.4

925

19.2

797

Washington

4,390

741

16.9

1,531

34.9

949

21.6

954

21.7

19

0.4

Virginia

4,199

1,359

32.4

1,381

32.9

190

4.5

238

5.7

587

14.0

Maryland

3,891

1,231

31.6

244

6.3

1,632

41.9

221

5.7

368

9.5

North Carolina

3,767

1,269

33.7

883

23.4

120

3.2

881

23.4

111

2.9

Ohio

3,597

574

16.0

776

21.6

644

17.9

982

27.3

525

14.6

New Jersey

3,365

1,022

30.4

608

18.1

1,444

42.9

117

3.5

112

3.3

Minnesota

2,981

879

29.5

1,279

42.9

179

6.0

249

8.4

150

5.0

Figure C2

New Money Long-Term Tax-Exempt Private Activity Bonds, by Selected Bond Purpose, for Top 15 States,

Ranked by Total Tax-Exempt Private Activity Bond Issuance, 2008

[Money amounts are in millions of dollars]

Selected bond purpose

Total

State of issue

Qualified section 501(c)(3)

nonhospital

Qualified hospital

Qualified mortgage

Qualified residential rental

All other bonds, combined

[2]

Amount

Amount

Percent of

State total

Amount

Percent of

State total

Amount

Percent of

State total

Amount

Percent of

State total

Amount

Percent of

State total

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

(10)

(11)

52,488

18,600

35.4

12,743

24.3

5,076

9.7

4,573

8.7

4,150

5,488

1,786

32.5

553

10.1

639

11.6

1,158

21.1

0

0.0

New York

5,398

2,654

49.2

612

11.3

291

5.4

1,031

19.1

368

6.8

Pennsylvania

3,030

1,718

56.7

567

18.7

d

d

d

d

0

0.0

Louisiana

2,453

94

3.8

d

d

d

d

35

1.4

2,093

85.3

Massachusetts

2,408

1,414

58.7

552

22.9

160

6.6

98

4.1

d

d

Texas

2,212

920

41.6

224

10.1

0

0.0

143

6.5

d

d

Ohio

2,197

360

16.4

1,246

56.7

357

16.2

73

3.3

0

0.0

New Jersey

2,089

622

29.8

567

27.1

d

d

d

d

d

d

Florida

2,058

878

42.7

194

9.4

d

d

195

9.5

0

0.0

Illinois

1,902

448

23.6

1,161

61.0

0

0.0

156

8.2

0

0.0

Virginia

1,726

358

20.7

485

28.1

d

d

79

4.6

d

d

Missouri

1,638

404

24.7

832

50.8

d

d

d

d

d

d

Georgia

1,530

956

62.5

379

24.8

d

d

88

5.8

0

0.0

Maryland

1,269

613

48.3

392

30.9

113

8.9

113

8.9

0

0.0

Minnesota

1,069

430

40.2

477

44.6

d

d

42

3.9

d

d

Total, All States

California

d - Data deleted to avoid disclosure of information about specific bonds. However, the data are included in the appropriate totals.

[1] For purposes of this figure, "other purposes" refers to obligations for which a specific purpose either did not apply or was not clearly indicated on the Form 8038-G. It does not include specific purposes, such as public safety and

housing, that are not shown separately in the figure. See Table 1.

130

[2] For purposes of this figure, certain bond purposes were combined. For this reason, data in this figure will differ slightly from the data in Tables 8 and 9.

NOTE: Detail may not add to totals because of rounding.

7.9

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

for education. In contrast, 28.7 percent of long-term

governmental bonds issued in New York and 16.0

percent in Ohio were for the same purpose.

Transportation projects accounted for 14.4 percent of States’ total new money long-term proceeds.

In New Jersey, however, 42.9 percent of the total

new money long-term governmental bond proceeds

were for transportation, while in North Carolina,

only 3.2 percent was allocated for the same purpose.

Transportation bonds accounted for only 4.5 percent

of Virginia’s total amount of new money long-term

bond issues.

Pennsylvania allocated 1.0 percent of its total

amount of new money long-term bonds to utility

projects, considerably less than the U.S. total (13.5

percent). In contrast, Ohio and North Carolina

each spent a large portion of their total allocation

on utility projects—27.3 percent and 23.4 percent,

respectively.

Total new money long-term tax-exempt private

activity bond volume decreased by $34.1 billion

(39.4 percent) from 2007 to 2008. California experienced the largest absolute decrease in new money

long-term tax-exempt private activity bond issuance,

from $10.5 billion in 2007 to approximately $5.5

billion in 2008. States with significant relative decreases in new money long-term tax-exempt private

activity bonds from 2007 to 2008 included Texas,

whose issuance fell 47.9 percent, from $5.1 billion

in 2007 to $2.2 billion in 2008; New York, whose issuance fell 34.1 percent, from $8.2 billion in 2007 to

$5.4 billion in 2008; and Illinois, whose issuance fell

49.7 percent, from $3.8 billion in 2007 to $1.9 billion

in 2008. For the 45 States that reduced their issuance

of new money long-term tax-exempt private activity

bonds in 2008, the overall reduction totaled $35.6

billion.

New Jersey experienced the largest relative

increase (25.3 percent) in new money long-term

tax-exempt private activity bond issues, from nearly

$1.7 billion in 2007 to $2.1 billion in 2008. States

with significant increases in new money long-term

tax-exempt private activity bond issues from 2007 to

2008 included Missouri, whose issuance increased

17.4 percent, from $1.4 billion in 2007 to $1.6 billion in 2008; and Virginia, whose issuance increased

6.9 percent from $1.6 billion in 2007 to $1.7 billion

in 2008. In all, six States increased their issuance of

new money long-term tax-exempt private activity

bonds from 2007 to 2008, by $1.1 billion.

Combined, the top 15 States accounted for 69.5

percent of the total $52.5 billion of new money longterm tax-exempt private activity bond issues for

the year. Almost $18.8 billion (35.8 percent of the

total) was issued by authorities in the following five

States: California (10.5 percent), New York (10.3

percent), Pennsylvania (5.8 percent), Louisiana (4.7

percent), and Massachusetts (4.6 percent). According

to 2008 Census estimates, together, these five States

accounted for almost 26.2 percent of the total U.S.

population.

Similar to governmental bond issuance, there

were differences in the composition of total new

money long-term tax-exempt private activity bond

issuance, by purpose, among the States. Examining

the bond allocations by purpose for 2008, overall,

35.4 percent of the amount of new money long-term

private activity bonds was issued for qualified IRC

section 501(c)(3) nonhospital organizations. Another

24.3 percent was issued for qualified hospital bonds.

Of the total amount of new money long-term taxexempt private activity bonds issued in Georgia, 62.5

percent was issued for IRC section 501(c)(3) nonhospital organizations, compared to 16.4 percent in Ohio

and 3.8 percent in Louisiana for the same purpose.

Qualified hospital bonds accounted for 61.0 percent

of Illinois’ new money long-term tax-exempt private activity bond issues, compared to 10.1 percent

in both California and Texas. Of the top 15 States,

Florida had the lowest total issuance for qualified

hospitals in both dollar amount ($194 million) and

percent (9.4 percent) of its State total.

Qualified mortgage bonds accounted for 9.7 percent of all new money long-term tax-exempt private

activity bonds issued in 2008, totaling almost $5.1

billion. Ohio committed 16.2 percent of its total

new money long-term private activity bond issuance

toward qualified mortgages; in contrast, Texas and

Illinois issued no new money long-term qualified

mortgage bonds.

Together, States allocated only 8.7 percent of the

$52.5 billion of new money long-term tax-exempt

private activity bonds in 2008 for qualified residential rental projects. However, both California and

New York directed a much larger share of their total

new money long-term proceeds to this purpose, 21.1

percent and 19.1 percent, respectively.

Tax-exempt private activity bonds are subject

to State volume limitations, or volume caps. Most

131

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

types of private activity bonds are subject to the unified State volume cap, which limits the aggregate

dollar amount of bonds that each State can issue

annually. For each of the qualified issue types subject to the unified volume cap, there is no specific

limit on the dollar amount of issuance; rather, each

State must allocate issuance authority in such a way

that the combined issuance does not exceed the annual volume cap. The unified State volume cap

is adjusted annually for population growth and is

also indexed for inflation.11 Other types of private

activity bonds are subject to separate volume limitations based on the specific bond purpose, or types of

projects being financed. Refunding bonds are not

subject to volume cap limitations, as long as there is

no increase in the principal amount of the outstanding bond. Issuers can elect to carry forward unused

volume cap for a specified bond purpose, and bonds

issued with respect to the specified bond purpose

during the following 3 calendar years are not subject

to the volume cap.

Figure D shows the total amount of new money

long-term tax-exempt private activity bond issuance,

new issues subject to the unified State volume cap,

amounts applied from prior-year carryforward elections, and volume cap allocations, by State, for 2008.

States issued $14.9 billion of new money private activity bonds that were subject to unified State volume

cap. States elected to apply a total of $6.1 billion

of volume cap carried forward from previous years.

Each of the States used some amount of carryforward

in 2008. Total current-year volume cap allocation

for all States was $28.8 billion. None of the States

exhausted its current-year volume cap allocation,

and, therefore, will have amounts to carry forward to

future years.

Unlike private activity bonds, governmental

bonds are generally not subject to the volume cap;

however, if more than $15 million of the proceeds of

an issue are used in private use or disproportionate

use, then the amount in excess of $15 million is subject to the volume cap, and the issuer is required to

report the amount of the State volume cap allocated

to the governmental issue.12, 13 For 2008, issuers re-

132

ported allocating a combined $38.4 million of State

volume cap to the total $334.4 billion of governmental bond issues. This indicates some private business involvement, but not in an amount sufficient to

satisfy the 10-percent private activity use criteria for

each governmental bond issue.

Summary

More than 24,000 tax-exempt governmental bonds

were issued in 2008, raising $334.4 billion in proceeds for public projects such as schools, transportation infrastructure, and utilities. Of the $271.7

billion of long-term governmental bonds issued,

$153.8 billion of proceeds were used to finance new

projects, while the remaining $117.9 billion of proceeds refunded prior governmental bond issues. In

addition, more than 3,400 tax-exempt private activity

bonds were issued in 2008, for a total $135.0 billion in proceeds. These tax-exempt private activity

bond proceeds financed qualified private facilities

(such as residential rental facilities, single family

housing, and airports), as well the facilities of Internal Revenue Code section 501(c)(3) organizations

(such as hospitals and private universities). Of the

$132.8 billion of long-term private activity bonds issued, $52.5 billion of proceeds were used to finance

new projects, while the remaining $80.3 billion of

proceeds refunded prior tax-exempt private activity

bond issues.

Data Sources and Limitations

The data presented in this article are based on the

populations of Forms 8038 and Forms 8038-G filed

with the Internal Revenue Service for bonds issued

during Calendar Year 2008. The data exclude returns

filed for commercial paper transactions, as well as issues that are loans from the proceeds of another taxexempt bond issue (pooled financings). Additionally, except where specifically mentioned, the data

exclude returns filed for tax credit bonds, which are

treated separately for the purpose of this article.

Bond issuers were required to file these tax-exempt bond information returns by the 15th day of the

second calendar month after the close of the calendar

11 For 2008, the volume cap was the greater of $85 per capita or $262,095,000. Volume caps for U.S. possessions, with the exception of Puerto Rico, are determined under

IRC section 146(d)(4).

12 Disproportionate use occurs when the proceeds to be used for the private business use exceed the amount of proceeds used for the related governmental use.

13 IRC section 141(b)(5) states that a governmental bond will be treated as a private activity bond if: (1) the “nonqualified amount” exceeds $15 million, but is less than the

amount needed to meet any of the private activity bond tests; and (b) the issuer does not allocate a portion of its volume cap to the issue in an amount equal to the excess of

such nonqualified amount greater than $15 million.

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Figure D

New Money Long-Term Tax-Exempt Private Activity Bonds, Carryforward, and Volume Cap, by State

of Issue, 2008

[Money amounts are in millions of dollars]

State of issue

Total, All States

Alabama

Alaska

Arizona

Arkansas

California

Colorado

Connecticut

Delaware

District of Columbia

Florida

Georgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Maryland

Massachusetts

Michigan

Minnesota

Mississippi

Missouri

Total amount of bonds

issued

Amount subject to

the unified State

volume cap [1]

Amount not subject to the

volume cap

under a carryforward

election [2]

Total volume

cap allocation [3]

(1)

(2)

(3)

(4)

52,487.5

768.1

191.8

1,044.8

165.2

5,487.9

826.6

610.8

161.3

726.3

2,058.2

1,530.3

d

370.3

1,902.0

903.5

475.9

215.6

803.7

2,452.7

253.1

1,269.4

2,408.1

630.8

1,069.3

629.1

1,637.7

14,907.3

202.6

d

146.0

50.4

2,361.9

137.0

199.0

115.2

65.3

602.4

189.3

d

175.4

283.8

365.2

90.1

91.6

253.9

227.0

137.0

264.1

442.2

144.7

161.3

69.0

398.7

6,052.0

164.0

d

d

d

942.2

d

d

d

60.2

530.9

103.1

d

133.8

175.3

d

d

d

d

92.6

126.8

204.8

d

d

d

d

d

28,843.3

393.4

262.1

538.8

262.1

3,107.0

413.2

297.7

262.1

262.1

1,551.4

811.3

d

262.1

1,092.5

539.3

262.1

262.1

360.5

364.9

262.1

477.6

548.2

856.1

441.8

262.1

499.7

Footnotes at end of figure.

quarter in which the bond was issued. However, in

an effort to include as many applicable returns for

a particular issue year as possible, the study period

extended well beyond this timeframe. The study

includes returns processed from January 1, 2008, to

May 2, 2010, for bonds issued in 2008. Where possible, data from amended returns filed and processed

before the cutoff date were included. Late-filed

returns for tax-exempt bonds issued during 2008 processed after the cutoff date were not included in the

statistics.

During statistical processing, returns were subject to thorough testing and correction procedures to

ensure data accuracy and validity. Additional checks

were conducted to identify and exclude duplicate

returns. Wherever possible, returns with incomplete

information, mathematical errors, or other reporting

anomalies were edited to resolve internal inconsistencies. However, in other cases, it was not possible

to reconcile reporting discrepancies. Thus, some reporting and processing error may remain.

Explanation of Selected Terms

Commercial paper—Commercial paper consists

of short-term notes that are continually rolled-over.

Maturities average about 30 days but can extend up

to 270 days. Many localities use commercial paper

to raise cash needed for current transactions.

Enterprise Zone facility bond—Established by

the passage of the Revenue Reconciliation Act of

1993, this type of exempt facility bond may be issued

for certain businesses in “empowerment zones” or

“enterprise communities.” Empowerment Zone and

Enterprise Community designations are made by the

133

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Figure D—Continued

New Money Long-Term Tax-Exempt Private Activity Bonds, Carryforward, and Volume Cap, by State of

Issue, 2008—Continued

[Money amounts are in millions of dollars]

State of issue

Montana

Nebraska

Nevada

New Hampshire

New Jersey

New Mexico

New York

North Carolina

North Dakota

Ohio

Oklahoma

Oregon

Pennsylvania

Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

Vermont

Virginia

Washington

West Virginia

Wisconsin

Wyoming

U.S. Possessions [4]

Total amount of bonds

issued

Amount subject to

the unified State

volume cap [1]

(1)

(2)

538.5

657.4

815.9

554.4

1,666.7

323.2

8,192.6

1,434.6

440.9

2,638.3

461.4

656.6

4,533.4

357.1

862.5

386.5

1,787.3

5,079.1

602.1

349.9

1,614.2

2,380.2

400.3

1,190.7

315.7

d

360.8

566.7

302.4

265.7

730.3

278.5

2,020.0

826.0

362.7

942.3

298.6

226.0

1,283.7

262.2

383.0

290.5

1,260.5

1,848.0

292.4

274.6

789.1

761.4

248.1

526.1

306.7

d

Amount not subject to the

volume cap

under a carryforward

election [2]

(3)

208.1

500.0

135.9

83.1

796.3

63.6

645.5

359.0

305.2

330.5

33.0

161.8

508.8

262.6

48.3

240.7

1,036.6

264.3

112.8

27.6

561.4

128.3

196.8

275.5

215.7

d

Total volume

cap allocation [3]

(4)

256.2

256.2

256.2

256.2

741.6

256.2

1,641.0

752.8

256.2

975.6

304.2

314.6

1,057.5

256.2

367.3

256.2

513.3

1,998.2

256.2

256.2

649.6

543.6

256.2

472.3

256.2

d

d -Data deleted to avoid disclosure of information for specific bonds when compared to other published data. However, the data are included in the appropriate totals.

[1] These calculations are based on the data reported on Part II of Form 8038, for type of issue, and include the following: mass commuting facilities, water furnishing facilities, sewage

facilities, solid waste disposal facilities, qualified residential rental projects, local electric energy or gas furnishing facilities, local district heating and cooling facilities, qualified

hazardous waste facilities, high-speed intercity rail facilities, qualified mortgage bonds, qualified small issue bonds, qualified student loan bonds, and qualified redevelopment bonds.

No distinction was made for governmentally-owned solid waste or high-speed intercity rail facilities (which are not subject to the volume cap). As a result, figures could be slightly

[2] As reported on Form 8038, line 44b. An issuing authority can elect to carry forward its unused volume cap for one or more carryforward purposes (see IRC section 146(f)). If the

election is made, bonds issued with respect to a specified carryforward purpose are not subject to the volume cap under IRC section 146(a) during the 3 calendar years following the

calendar year in which the carryforward arose, but only to the extent that the amount of such bonds does not exceed the amount of the carryforward elected for that purpose.

[3] The volume cap amount was calculated based on State population estimates produced by the U.S. Bureau of the Census and published in Internal Revenue Bulletin Number 2008-8

(Notice 2008-22). For 2008, the volume cap was the greater of $85 per capita or $262.1 million.

[4] U.S. possessions include Puerto Rico, the U.S. Virgin Islands, Guam, and the Northern Mariana Islands.

NOTE: Detail may not add to totals because of rounding.

134

Secretaries of Agriculture and Housing and Urban

Development and last for a 10-year period. The Taxpayer Relief Act of 1997 provided certain economically depressed census tracts within the District of

Columbia designation as the “District of Columbia

Enterprise Zone.” Qualified enterprise zone facility

bonds are generally subject to the same rules as exempt facility bonds.

Exempt facility bond—Bond issue of which 95

percent or more of the net proceeds is used to finance

a tax-exempt facility (as listed in IRC sections 142(a)

(1) through (15) and 142(k)). These facilities include

airports, docks and wharves, mass commuting facilities, facilities for the furnishing of water, sewage

facilities, solid waste disposal facilities, qualified residential rental projects, facilities for the local furnishing of electric energy or gas, local district heating or

cooling facilities, qualified hazardous waste facilities,

high-speed intercity rail facilities, environmental enhancements of hydroelectric generating facilities, and

qualified public educational facilities.

Governmental bond—Any obligation issued by

a State or local government unit that is not a private

activity bond (see below). The interest on a govern-

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

mental bond is excluded from gross income under

IRC section 103.

Gulf Opportunity Zone bond—The Gulf Opportunity Zone Act of 2005, signed into law as Public

Law 109-135 on December 21, 2005, authorized a

new category of tax-exempt bonds. The proceeds of

such bonds are used to finance the construction and

rehabilitation of certain residential and nonresidential property located in certain localities in Alabama,

Louisiana, and Mississippi, designated as the “Gulf

Opportunity Zone.” This area constitutes the portion

of the Hurricane Katrina disaster area determined by

the President to warrant individual or individual and

public assistance from the Federal government, under

the Robert T. Stafford Disaster Relief and Emergency

Assistance Act.

IRC section 1400N(a)(2) defines a qualified Gulf

Opportunity Zone Bond as any bond issued as part of

an issue if it meets the following requirements: (1)

95 percent or more of the net proceeds is to be used

for qualified project costs, or such issue meets the

requirements of a qualified mortgage issue, except

as otherwise provided in IRC section 1400N(a); (2)

such bond is issued by the State of Alabama, Louisiana, or Mississippi or any political subdivision

thereof; (3) such bond is designated for purposes

of IRC section 1400N(a) either by the Governor, or

approved bond commission, of such State; (4) the

bond is issued after December 21, 2005, and before

January 1, 2011; and (5) no portion of the proceeds

of such issue is to be used to provide any property

described in IRC section 144(c)(6)(B).

Gulf Opportunity Zone bonds that meet the general requirements of a qualified mortgage bond issue,

and the proceeds of such bond issues that finance

residences located in the Gulf Opportunity Zone,

shall be treated as qualified mortgage bonds (“Gulf

Opportunity Zone Mortgage Bonds”), as described

in IRC section 1400N(a)(2)(A)(ii). The Act also

authorized the issuance of “Gulf Opportunity Zone

Advance Refunding Bonds,” which allow for an additional advance refunding for certain bonds, issued

by the States of Alabama, Louisiana, or Mississippi

(or any political subdivision thereof), and outstanding on August 28, 2005. This provision was effective

for bonds issued between December 21, 2005, and

January 1, 2011. (See Internal Revenue Service Notice 2006-41, Internal Revenue Bulletin 2006-18, for

additional information.)

New York Liberty Zone bonds—The Job Creation

and Worker Assistance Act of 2002 created Section

1400L of the Internal Revenue Code of 1986 to provide various tax benefits for the area of New York

City damaged or affected by the terrorist attack on

September 11, 2001. IRC section 1400L(d) authorizes the issuance of an additional type of exempt facility bond, namely, “Liberty Bonds.” Liberty Bonds

are subject to the following additional requirements:

(1) 95 percent or more of the net proceeds of such

issue must be used for qualified project costs; (2) the

bond must be issued by the State of New York or any

political subdivision thereof; (3) the Governor of the

State of New York or the Mayor of the City of New

York must designate the bond for purposes of section 1400L(d); and (4) the bond must be issued after

March 9, 2002, and before January 1, 2005. The

maximum aggregate face amount of bonds that may

be designated as Liberty Bonds is $8 billion.

Nongovernmental output property bond—Bonds

used to finance the acquisition of property used by a

nongovernmental entity in connection with an output

facility (such as an electric or gas power project).

This bond must meet additional tests under IRC section 141(d).

Pooled financing— An arrangement whereby a

portion of the proceeds of a governmental bond issue

is used to make loans to other governmental units.

Private activity bond—Bond issue of which more

than 10 percent of the proceeds is used for any private business use, and more than 10 percent of the

payment of the principal or interest is either secured

by an interest in property to be used for private business use (or payment for such property), or is derived

from payments for property (or borrowed money)

used for a private business use. A bond is also considered a private activity bond if the amount of the

proceeds used to make or finance loans (other than

loans described in IRC section 141(c)(2)) to persons

other than governmental units exceeds the lesser of 5

percent of the proceeds or $5 million.

Qualified green building and sustainable design

project—Bond issue of which 95 percent or more of

the net proceeds is used to finance qualified green

building and sustainable design projects, as designated by the Secretary of the Treasury, after consultation with the Administrator of the Environmental

Protection Agency. The project must be nominated

by a State or local government, and the issuer must

135

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

submit a detailed application to the Treasury Department for consideration, and, on approval, allocation

of a specified issuance amount. Section 701 of the

American Jobs Creation Act of 2004 added IRC sections 142(a)(14) and 142(l), authorizing up to $2 billion of tax-exempt private activity bonds, not subject

to the unified volume cap, for qualified green building and sustainable design projects, to be issued

between December 31, 2004, and October 1, 2009.

(See Internal Revenue Service Notice 2006-41,

Internal Revenue Bulletin 2006-18, for additional

information.)

Qualified highway or surface transfer freight

facility bond—Bond issue of which 95 percent or

more of the net proceeds is used to provide qualified

highway or surface freight transfer facilities. Section

11143 of the Safe, Accountable, Flexible, Efficient,

Transportation Equity Act: A Legacy for Users (SAFETEA-LU) Public Law 109-59, signed into law on

August 10, 2005, added IRC sections 142(a)(15) and

142(m). Section 142(m)(1) defines the term “qualified highway or surface freight transfer facilities” as:

(a) any surface transportation project that receives

Federal assistance under title 23, United States Code

(as in effect on August 10, 2005); (b) any project for

an international bridge or tunnel for which an international entity authorized under Federal or State law

is responsible and that receives Federal assistance

under title 23, United States Code (as so in effect);

or, (c) any facility for the transfer of freight from

truck to rail or rail to truck (including any temporary

storage facilities directly related to such transfers)

that receives Federal assistance under either title 23

or title 49, United States Code (as so in effect). This

legislation authorized issuance of up to $15 billion

of such bonds, not subject to the unified volume cap,

applicable to bonds issued after August 10, 2005.

Allocation of the $15-billion national limitation is

under the jurisdiction of the Department of Transportation. (See Internal Revenue Service Notice 200645, Internal Revenue Bulletin 2006-20, for additional

information.)

Qualified mortgage bond—Bond issue of which

the proceeds (except issuance costs and reasonably

required reserves) are used to provide financing assistance for single-family residential property, and

which meets the additional requirements in IRC section 143. Bond proceeds can be applied toward the

purchase, improvement, or rehabilitation of owner136

occupied residences, as well as to finance qualified

home-improvement loans.

Qualified public educational facility bond—

Bond issue of which 95 percent or more of the net

proceeds is used to provide qualified public educational facilities, defined by IRC section 142(k)(1)

as any school facility that is: (a) part of a public elementary or secondary school; and (b) is owned by a

private, for-profit corporation under a public-private

partnership agreement with a State or local educational agency. Under a “public-private partnership

agreement,” the corporation agrees to construct,

rehabilitate, refurbish, or equip a school facility and,

at the end of the term of the agreement, to transfer

the school facility to the State or local educational

agency for no additional consideration. Such bonds

are not subject to the unified volume cap; rather, the

annual State limit is equal to the lesser of $10 per

resident or $5 million.

Qualified redevelopment bond—Bond issue of

which 95 percent or more of the net proceeds is used

to finance certain specified real property acquisition

and redevelopment in blighted areas (see IRC section

144(c) for additional requirements).

Qualified section 501(c)(3) bond— Bonds issued by State and local governments to finance the

activities of charitable organizations that are tax

exempt under IRC section 501(c)(3). A bond must

meet the following conditions to be classified as a

section 501(c)(3) bond: 1) all property financed by

the net proceeds of the bond issue is to be owned by

a section 501(c)(3) organization or a governmental

unit; and 2) the bond would not be a private activity

bond if section 501(c)(3) organizations were treated

as governmental units with respect to their activities that are not related trades or businesses, and the

private activity bond definition was applied using a

5-percent threshold rather than a 10-percent threshold. The primary beneficiaries of these bonds are

private, nonprofit hospitals, colleges, and universities. A qualified hospital bond issue is one in which

95 percent or more of the net proceeds is to be used

for a hospital.

Qualified small issue bond—Bond issue generally not exceeding $1 million, and of which 95 percent or more of the net proceeds is used to finance

the acquisition of land and depreciable property or

to refund such issues. In certain instances, an election to take certain capital expenditures into account

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

can increase the limit on bond size, from $1 million

to $10 million. These bonds may only be used to

finance manufacturing facilities and to benefit certain

first-time farmers.

Qualified student loan bond—Bond issue of

which 90 percent or more of the net proceeds is used

to make or finance student loans under a program

of general application subject to the Higher Education Act of 1965 (see IRC section 144(b)(1)(A) for

additional requirements), or of which 95 percent or

more of the net proceeds is used to make or finance

student loans under a program of general application

approved by the State (see Code section 144(b)(1)(B)

for additional requirements).

Qualified veterans’ mortgage bond— In general,

a bond issue of which 95 percent or more of the net

proceeds is used to finance the purchase, improvement, or rehabilitation of owner-occupied residences

for veterans who: 1) served prior to January 1, 1977;

and, 2) applied for such a mortgage prior to the date

30 years after leaving active service or January 31,

1985, whichever is later. The payment of interest

and principal must be secured by a general obligation of the State, and the bond must meet certain of

the requirements of IRC section 143. The issuance

of qualified veterans’ mortgage bonds was limited to

the following five states: Alaska, California, Oregon,

Texas, and Wisconsin, each of which had a veterans’

mortgage bond program in effect prior to June 22,

1984.

Tax Reform Act transition property bond— A

bond issued under transitional rules contained in the

Tax Reform Act of 1986. Proceeds from bonds issued under these rules include issues used to fund

such items as pollution control facilities, parking

facilities, industrial parks, sports stadiums, and convention facilities. Proceeds from other bonds issued

under the transitional rules are included in this category only if they could not be identified as another

issue type.

137

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Table 1. Tax-Exempt Governmental Bonds, by

Type and Term of Issue, 2008

[Money amounts are in millions of dollars]

Type and term of issue

All issues, total [1]

Number

24,275

Amount

334,373

Short-term

6,780

62,688

Long-term

17,495

271,685

19,754

206,027

New money issues, total

Short-term

5,070

52,256

Long-term

14,684

153,771

6,535

128,346

Refunding issues, total

Short-term

2,375

10,432

Long-term

4,160

117,914

[1] A given bond issue can include both new money and refunding proceeds.

Thus, the number of new money issues plus the number of refunding issues will

sometimes exceed the total number of issues. However, the money amounts add

to the totals.

NOTE: Detail may not add to totals because of rounding.

Table 2. Long-Term Tax-Exempt Governmental Bonds, by Bond Purpose and Type of Issue, 2008

[Money amounts are in millions of dollars]

Bond purpose

Total [1]

Education

Health and hospital

Transportation

All issues

New money issues

Refunding issues

Number

Amount

Number

Amount

Number

Amount

(1)

(2)

(3)

(4)

(5)

(6)

17,495

271,685

14,684

153,771

4,160

117,914

5,840

78,011

4,810

50,313

1,401

27,698

388

7,128

319

2,808

102

4,320

1,240

41,826

1,048

22,208

319

19,618

Public safety

2,210

6,774

2,090

3,994

235

2,780

Environment

1,261

15,902

984

8,509

466

7,393

Housing

99

664

67

296

39

368

Utilities

2,059

48,438

1,573

20,722

813

27,716

Bond and tax/revenue anticipation notes

Other purposes [2]

367

1,994

323

1,640

95

354

5,237

70,948

4,412

43,281

1,331

27,667

[1] A given bond issue can include more than one purpose and can include both new money and refunding proceeds. Thus, the summation of number of issues by purpose or by type of

issue will sometimes exceed the total number of issues. However, the money amounts add to the totals.

[2] "Other purposes" refers to obligations for which a specific purpose either did not apply or was not clearly indicated on the Form 8038-G, Informational Return for Tax-Exempt

Governmental Obligations Bonds.

NOTE: Detail may not add to totals because of rounding.

138

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Table 3. Computation of Lendable Proceeds for Long-Term Tax-Exempt Governmental Bonds, by

Bond Purpose, 2007

[Money amounts are in millions of dollars]

Entire issue price

Bond purpose

Total [1]

Education

Health and hospital

Transportation

Public safety

Environment

Housing

Utilities

Bond and tax/revenue anticipation notes

Other purposes [2]

Bond purpose

Total [1]

Education

Health and hospital

Transportation

Public safety

Environment

Housing

Utilities

Bond and tax/revenue anticipation notes

Other purposes [2]

Credit

enhancement

Bond issuance

costs

Allocation to reserve fund

Number

Amount

Number

Amount

Number

Amount

Number

Amount

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

17,495

5,840

388

1,240

2,210

1,261

99

2,059

367

5,237

271,685

78,011

7,128

41,826

6,774

15,902

664

48,438

1,994

70,948

10,316

3,570

198

809

710

887

59

1,663

269

3,272

2,283

670

54

318

75

116

5

419

9

617

2,428

1,098

34

168

123

171

d

414

d

679

683

168

11

104

20

42

d

203

d

133

1,149

182

31

99

49

122

d

319

d

376

2,707

211

91

605

53

225

d

782

d

734

Total lendable proceeds

Proceeds used to refund

prior issues

Nonrefunding proceeds

Number

Amount

Number

Amount

Number

(9)

(10)

(11)

(12)

(13)

(14)

17,495

5,840

388

1,240

2,210

1,261

99

2,059

367

5,237

266,012

76,963

6,972

40,799

6,625

15,520

651

47,034

1,984

69,464

115,584

27,369

4,236

19,045

2,726

7,284

364

27,051

351

27,158

14,684

4,810

319

1,048

2,090

984

67

1,573

323

4,412

150,428

49,593

2,736

21,754

3,899

8,236

287

19,983

1,633

42,306

4,160

1,401

102

319

235

466

39

813

95

1,331

Amount

d—Data deleted to avoid disclosure of information about specific bonds. However, the data are included in the appropriate totals.

[1] A given bond issue can include more than one purpose. Thus, the summation of number of issues by purpose will sometimes exceed the total number of issues. However, the

money amounts add to the totals.

[2] "Other purposes" refers to obligations for which a specific purpose either did not apply or was not clearly indicated on the Form 8038-G, Informational Return for Tax-Exempt

Governmental Obligations Bonds.

NOTE: Detail may not add to totals because of rounding.

139

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Table 4. New Money Long-Term Tax-Exempt Governmental Bonds, by Bond Purpose and Size of

Entire Issue, 2008

[Money amounts are in millions of dollars, except for size of entire issue, which is in whole dollars]

Bond purpose

All issues

Under $500,000 [1]

Number

(1)

Total [2]

Education

Health and hospital

Transportation

Public safety

Environment

Housing

Utilities

Bond and tax/revenue anticipation notes

Other purposes [3]

Amount

(2)

14,684

4,810

319

1,048

2,090

984

67

1,573

323

4,412

153,771

50,313

2,808

22,208

3,994

8,509

296

20,722

1,640

43,281

Size of entire issue

$500,000

under

$1,000,000

$1,000,000

under

$5,000,000

Number

(3)

Amount

(4)

Number

(5)

Amount

(6)

Number

(7)

Amount

(8)

5,610

1,745

94

361

1,232

228

10

320

48

1,621

1,318

412

21

77

282

54

2

83

15

372

1,796

565

38

98

276

120

14

174

57

494

1,227

388

28

63

186

74

8

109

39

332

3,562

1,022

89

277

319

330

16

565

147

1,115

8,248

2,318

193

518

587

655

31

1,149

344

2,454

Size of entire issue—continued

$5,000,000

$10,000,000

$25,000,000

under

under

under

or

$10,000,000

$25,000,000

$75,000,000

more

Bond purpose

Number

(9)

Total [2]

Education

Health and hospital

Transportation

Public safety

Environment

Housing

Utilities

Bond and tax/revenue anticipation notes

Other purposes [3]

1,474

538

38

106

114

120

15

222

39

465

Amount

(10)

9,833

3,703

227

498

570

637

92

1,143

222

2,741

$75,000,000

Number

(11)

Amount

(12)

Number

(13)

Amount

(14)

Number

(15)

Amount

(16)

1,020

436

22

67

73

78

3

117

26

331

14,117

6,011

287

643

616

829

36

1,428

228

4,039

747

338

14

57

55

61

d

95

d

245

28,144

12,143

342

1,553

1,232

1,775

d

3,052

d

7,870

475

166

24

82

21

47

d

80

d

141

90,884

25,338

1,710

18,856

522

4,485

d

13,759

d

25,473

d—Data deleted to avoid disclosure of information about specific bonds. However, the data are included in the appropriate totals.

[1] Form 8038-G, Informational Return for Tax-Exempt Governmental Obligations Bonds, with an entire issue price less than $100,000 are excluded from the study. Issuers of

these bonds are instructed to file Form 8038-GC, Information Return for Small Tax-Exempt Governmental Bond Issues, Leases, and Installment Sales. Statistics of Income

(SOI) does not process data from Forms 8038-GC filed with the Internal Revenue Service.

[2] A given bond issue can include more than one purpose. Thus, the summation of number of issues by purpose will sometimes exceed the total number of issues. However,

the money amounts add to the totals.

[3] "Other purposes" refers to obligations for which a specific purpose either did not apply or was not clearly indicated on the Form 8038-G, Informational Return for TaxExempt Governmental Obligations Bonds.

NOTE: Detail may not add to totals because of rounding.

140

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Table 5. New Money Long-Term Tax-Exempt Governmental Bonds, by State of Issue and Bond

Purpose, 2008

[Money amounts are in millions of dollars]

Bond purpose

Total [1]

State of issue

All States

Alabama

Alaska

Arizona

Arkansas

California

Colorado

Connecticut

Delaware

District of Columbia

Florida

Georgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Maryland

Massachusetts

Michigan

Minnesota

Mississippi

Missouri

Montana

Nebraska

Nevada

New Hampshire

New Jersey

New Mexico

New York

North Carolina

North Dakota

Ohio

Oklahoma

Oregon

Pennsylvania

Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

Vermont

Virginia

Washington

West Virginia

Wisconsin

Wyoming

U.S. Possessions [3]

Education

Health and hospital

Transportation

Public safety

Number

Amount

Number

Amount

Number

Amount

Number

Amount

Number

Amount

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

(10)

14,684

254

30

274

202

954

262

113

27

12

338

398

12

72

857

378

365

257

243

181

125

153

239

463

573

243

380

63

473

50

77

385

145

743

514

138

376

381

131

661

35

226

68

199

1,302

149

79

238

199

104

482

54

7

153,771

1,131

308

5,688

642

15,918

2,816

2,354

489

432

10,594

4,813

725

563

5,770

2,007

1,215

1,123

1,815

1,012

442

3,891

1,734

2,393

2,981

1,147

1,799

176

914

2,465

428

3,365

1,486

15,310

3,767

357

3,597

1,838

1,356

5,171

328

1,381

304

1,734

21,593

1,692

123

4,199

4,390

243

2,435

188

1,129

4,810

50

11

128

94

335

74

43

d

0

59

92

0

16

425

147

94

80

122

31

53

38

76

159

135

40

144

19

54

10

22

211

48

374

69

36

128

279

50

232

7

52

16

42

378

21

16

86

55

9

118

29

d

50,313

521

105

1,755

354

5,510

842

137

d

0

2,725

1,282

0

165

1,847

1,208

382

511

616

368

56

1,231

451

1,310

879

320

714

71

192

859

17

1,022

344

4,392

1,269

76

574

762

347

1,933

125

396

54

292

10,962

290

75

1,359

741

125

533

37

d

2,808

11

0

d

d

383

39

d

0

0

52

d

d

0

14

5

d

19

0

72

0

69

d

34

35

d

37

d

15

0

0

5

114

441

174

d

35

34

d

d

0

64

d

61

447

29

0

135

55

0

43

13

0

1,048

21

d

17

7

76

16

19

11

d

23

9

d

5

50

20

23

34

13

10

22

17

d

32

46

14

49

4

29

4

9

7

8

44

18

10

30

14

8

35

d

d

5

d

57

16

8

14

19

5

110

d

0

22,208

37

d

858

8

1,098

74

352

174

d

732

791

d

182

1,659

39

34

50

172

85

153

1,632

d

80

179

14

274

49

10

180

18

1,444

216

3,012

120

9

644

151

135

1,291

d

d

2

d

3,656

749

2

190

949

1

455

d

0

2,090

27

d

41

15

106

46

35

7

0

59

75

0

11

71

74

22

16

d

48

d

35

57

50

31

42

37

d

36

5

15

69

32

92

161

0

57

16

18

110

8

62

6

32

156

25

15

53

26

46

84

6

d

3,994

12

d

413

18

288

65

41

17

0

158

165

0

25

149

115

59

31

d

78

d

95

45

88

160

14

41

d

32

16

12

43

22

53

317

0

45

21

39

149

3

88

17

48

403

106

3

232

92

34

92

2

d

319

6

0

d

d

30

6

d

0

0

4

d

d

0

7

3

d

8

0

15

0

9

d

16

6

d

13

d

12

0

0

11

6

9

10

d

5

11

d

d

0

6

d

4

34

6

0

7

9

0

11

6

0

Footnotes at end of table.

141

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Table 5. New Money Long-Term Tax-Exempt Governmental Bonds, by State of Issue and Bond

Purpose, 2008—Continued

[Money amounts are in millions of dollars]

Bond purpose—continued

State of issue

All States

Alabama

Alaska

Arizona

Arkansas

California

Colorado

Connecticut

Delaware

District of Columbia

Florida

Georgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Maryland

Massachusetts

Michigan

Minnesota

Mississippi

Missouri

Montana

Nebraska

Nevada

New Hampshire

New Jersey

New Mexico

New York

North Carolina

North Dakota

Ohio

Oklahoma

Oregon

Pennsylvania

Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

Vermont

Virginia

Washington

West Virginia

Wisconsin

Wyoming

U.S. Possessions [3]

Environment

Housing

Utilities

Bond and tax/revenue

anticipation notes

Other purposes [4]

Number

Amount

Number

Amount

Number

Amount

Number

Amount

Number

Amount

(11)

(12)

(13)

(14)

(15)

(16)

(17)

(18)

(19)

(20)

1,573

43

0

8

47

66

18

5

3

0

42

45

d

10

53

16

41

31

24

15

d

13

43

37

68

9

38

6

44

8

3

19

10

24

57

58

14

22

12

34

d

13

19

57

295

33

10

22

36

11

84

d

d

20,722

165

0

833

126

2,706

918

234

41

0

1,765

925

d

92

603

108

60

48

122

139

d

221

103

178

249

15

188

2

450

538

3

117

72

993

881

123

982

654

171

51

d

428

71

566

2,882

252

7

238

954

3

141

d

d

1,640

d

0

0

0

d

0

7

d

0

42

0

0

17

6

34

83

33

75

5

26

16

72

1

44

d

0

d

44

0

9

14

0

704

12

d

16

0

14

35

0

d

0

39

7

d

1

77

36

5

124

0

0

4,412

112

17

77

35

292

93

45

d

d

124

107

4

13

239

79

145

84

33

44

28

62

124

94

249

119

91

24

271

14

34

85

29

181

191

20

122

42

31

148

16

82

15

56

363

38

19

60

46

20

170

8

4

43,281

371

202

1,285

48

5,331

845

1,520

d

d

4,455

689

588

17

1,240

460

378

290

799

238

186

244

865

413

1,279

752

471

39

163

533

354

608

676

5,492

883

8

776

199

277

958

128

329

104

645

3,022

158

31

1,381

1,531

50

523

55

888

984

d

d

d

14

45

6

17

d

0

24

69

0

8

26

26

22

28

d

17

5

41

43

66

33

10

11

6

d

9

5

13

12

15

28

9

28

7

7

104

4

16

4

7

36

5

8

29

5

9

85

d

0

8,509

d

d

d

82

546

24

61

d

0

666

797

0

65

252

38

181

141

d

25

12

368

59

279

150

25

73

11

d

339

14

112

40

204

111

132

525

17

366

585

49

47

46

49

215

93

4

587

19

25

522

d

0

67

3

0

0

d

d

3

d

d

0

0

d

0

0

0

0

d

0

d

0

0

4

3

6

5

0

0

0

d

0

0

0

0

3

0

d

3

0

d

d

d

d

d

d

0

d

0

0

3

0

4

0

0

296

2

0

0

d

d

8

d

d

0

0

d

0

0

0

0

d

0

d

0

0

16

91

10

6

0

0

0

d

0

0

0

0

18

0

d

1

0

d

d

d

d

d

d

0

d

0

0

12

0

2

0

0

323

d

0

0

0

d

0

3

d

0

4

0

0

9

3

15

30

16

19

3

10

4

27

4

23

d

0

d

24

0

3

4

0

15

3

d

4

0

3

9

0

d

0

19

3

d

3

9

10

6

25

0

0

d—Data deleted to avoid disclosure of information about specific bonds. However, the data are included in the appropriate totals.

142

[1] A given bond issue can include more than one purpose. Thus, the summation of number of issues by purpose will sometimes exceed the total number of issues. However,

the money amounts add to the totals.

[2] U.S. possessions include Puerto Rico, the U.S. Virgin Islands, Guam, and the Northern Mariana Islands.

[3] "Other purposes" refer to obligations for which a specific purpose either did not apply or was not clearly indicated on the Form 8038-G, Informational Return for Tax-Exempt

Governmental Obligations Bonds .

NOTE: Detail may not add to totals because of rounding.

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Table 6. Tax-Exempt Private Activity Bonds, by Type

and Term of Issue, 2008

[Money amounts are in millions of dollars]

Type and term of issue

Number

All issues, total [1]

Amount

3,455

134,984

Short-term

76

2,161

Long-term

3,379

132,823

2,494

53,276

New money issues, total

Short-term

40

789

Long-term

2,454

52,488

1,462

81,708

Refunding issues, total

Short-term

39

1,372

Long-term

1,423

80,336

[1] A given bond issue can include both new money and refunding proceeds. Thus, the number of

ne mone

new

money iss

issues

es pl

plus

s the n

number

mber of ref

refunding

nding iss

issues

es will

ill sometimes e

exceed

ceed the total n

number

mber of

issues. However, the money amounts add to the totals.

NOTE: Detail may not add to totals because of rounding.

143

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Table 7. Long-Term Tax-Exempt Private Activity Bonds, by Bond Purpose and Type of Issue, 2008

[Money amounts are in millions of dollars]

Bond purpose

All issues

Number

Amount

(1)

New money issues

Number

Amount

(2)

(3)

Refunding issues

Number

Amount

(4)

(5)

(6)

Total [1]

3,379

132,823

2,454

52,488

1,423

80,336

Airports

74

9,209

31

1,753

54

7,457

Docks and wharves

Water, sewage, and solid waste disposal

facilities

24

1,244

15

345

11

899

117

3,643

88

2,575

35

1,068

Qualified residential rental facilities

391

7,030

312

4,573

87

2,456

Local electricity or gas furnishing facilities

2008 Housing Act under section 142 and

section 143

Tax Reform Act of 1986 transition property

bonds

11

399

d

d

d

d

6

232

d

d

d

d

66

4,137

d

d

d

d

Qualified highway or surface freight transfer

facilities

d

d

d

d

d

d

Qualified Gulf Opportunity Zone and

Gulf Opportunity Zone mortgage bonds

62

2,949

d

d

d

d

Qualified New York Liberty Zone bonds

d

d

d

d

d

d

143

10,669

94

5,076

100

5,593

Qualified mortgage bonds

Qualified veterans' mortgage bonds

Qualified small issue bonds

4

135

d

d

d

d

584

1,391

512

1,270

85

121

Qualified student loan bonds

24

4,213

14

1,404

16

2,809

Qualified hospital facilities

Qualified section 501(c)(3) nonhospital

bonds

484

48,598

259

12,743

320

35,855

1,434

37,782

1,084

18,600

672

19,183

Nongovernmental output property bonds

Gulf Opportunity Zone advance refunding

bonds

d

d

0

0

d

d

d

d

0

0

d

d

Other purposes [2]

11

383

7

57

5

326

d - Data deleted to avoid disclosure of information about specific bonds. However, the data are included in the appropriate totals.

[1] A given bond issue can include more than one purpose and can include both new money and refunding proceeds. Thus, the summation of number of issues by purpose or by

type of issue will sometimes exceed the total number of issues. However, the money amounts add to the totals.

[2] For this table, "other purposes" refers to obligations for which a specific purpose either did not apply or was not clearly indicated on the Form 8038, Informational Return for

Tax-Exempt Private Activity Bond Issues .

NOTE: Detail may not add to totals because of rounding.

144

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Table 8. Computation of Lendable Proceeds for Long-Term Tax-Exempt Private Activity Bonds, by

Selected Bond Purpose, 2008

[Money amounts are in millions of dollars]

Selected bond purpose

Total [1]

Airports

Docks and wharves

Water, sewage, and solid waste disposal

facilities

Qualified residential rental facilities

Qualified mortgage bonds

Qualified small issue bonds

Qualified student loan bonds

Qualified hospital facilities

Qualified section 501(c)(3) nonhospital

bonds

All other bonds, combined [3]

Entire issue price

Bond issuance costs

Credit enhancement

Allocation to reserve fund

Number

(1)

3,379

74

Amount

(2)

132,823

9,209

Number

(3)

1,996

58

Amount

(4)

839

54

Number

(5)

803

29

Amount

(6)

362

52

Number

(7)

365

24

Amount

(8)

1,459

227

24

1,244

d

d

5

3

d

d

117

391

143

584

24

484

3,643

7,030

10,669

1,391

4,213

48,598

66

87

34

199

d

375

26

21

18

15

d

350

22

26

3

d

d

176

7

6

[2]

d

d

169

16

16

33

d

7

68

23

39

63

d

50

626

1,434

164

37,782

9,044

1,140

59

318

27

472

23

105

12

203

7

428

3

Total lendable proceeds

Proceeds used to refund

prior issues

Nonrefunding proceeds

Number

(9)

Number

(11)

Number

(13)

Selected bond purpose

Total [1]

Airports

Docks and wharves

Water, sewage, and solid waste disposal facilities

Qualified residential rental facilities

Qualified mortgage bonds

Qualified small issue bonds

Qualified student loan bonds

Qualified hospital facilities

Qualified section 501(c)(3) nonhospital bonds

All other bonds, combined [3]

Amount

(10)

Amount

(12)

Amount

(14)

3,379

74

24

117

391

143

584

24

484

1,434

130,164

8,876

1,234

3,587

6,963

10,588

1,372

4,157

47,453

36,932

1,423

54

11

35

87

100

85

16

320

672

78,933

7,196

894

1,068

2,420

5,566

121

2,797

35,137

18,842

2,520

33

17

88

313

95

512

14

278

1,129

51,230

1,680

340

2,519

4,543

5,021

1,251

1,361

12,315

18,089

164

9,002

87

4,891

81

4,111

d—Data deleted to avoid disclosure of information for specific bonds. However, the data are included in the appropriate totals.

[1] A given bond issue can include more than one purpose. Thus, the summation of number of issues by purpose will sometimes exceed the total number of issues. However, the

money amounts add to the totals.

[2] Indicates an amount less than $500,000.

[3] For purposes of this table, this category includes all issues for which a specific purpose either did not apply or was not clearly indicated on the Form 8038, Informational Return for

Tax-Exempt Private Activity Bond Issues, as well as bonds issued for: local electricity or gas furnishing facilities, facilities issued under a transitional rule of the Tax Reform Act of 1986,

qualified highway or surface freight transfer facilities, Gulf Opportunity Zone bonds, Gulf Opportunity Zone mortgage bonds, New York Liberty Zone bonds, qualified veterans' mortgage

bonds, nongovernmental output property bonds, Gulf Opportunity Zone advance refunding bonds, and 2008 Housing Act bonds issued under IRC section 142 or 143.

NOTE: Detail may not add to totals because of rounding.

145

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Table 9. New Money Long-Term Tax-Exempt Private Activity Bonds, by Selected Bond Purpose and

Size of Entire Issue, 2008

[Money amounts are in millions of dollars, except for size of entire issue, which is in whole dollars]

Size of entire issue

All issues

$5,000,000 under

$10,000,000

$1,000,000 under

$5,000,000

Under $1,000,000

Selected bond purpose

Number

Amount

Number

Amount

Number

Amount

Number

Amount

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

2,454

31

15

52,488

1,753

345

337

d

d

93

d

d

579

10

d

1,540

30

d

497

5

3

3,255

32

25

Water, sewage, and solid waste

disposal facilities

Qualified residential rental facilities

Qualified mortgage bonds

Qualified small issue bonds

88

312

94

512

2,575

4,573

5,076

1,270

4

d

0

260

1

d

0

53

15

69

d

133

46

214

d

359

7

94

0

91

45

687

0

588

Qualified student loan bonds

Qualified hospital facilities

14

259

1,404

12,743

0

7

0

4

0

38

0

107

0

30

0

226

1,084

18,600

55

30

299

738

248

1,520

81

4,150

d

d

d

d

19

132

Total [1]

Airports

Docks and wharves

Qualified section 501(c)(3) nonhospital

bonds

All other bonds, combined [2]

Size of entire issue—continued

Selected bond purpose

Total [1]

Airports

Docks and wharves

Water, sewage, and solid waste

disposal facilities

Qualified residential rental facilities

Qualified mortgage bonds

Qualified small issue bonds

$10,000,000 under

$25,000,000

$25,000,000 under

$50,000,000

$50,000,000 under

$100,000,000

$100,000,000 or more

Number

Amount

Number

Amount

Number

Amount

Number

Amount

(9)

(10)

(11)

(12)

(13)

(14)

(15)

(16)

713

5

0

9,646

75

0

365

d

d

10,321

d

d

261

3

d

13,122

172

d

287

15

d

46,334

3,202

d

5

d

35

168

77

d

554

2,445

3

0

28

44

125

0

971

1,463

d

3

16

14

d

89

972

790

0

d

7

8

0

d

660

1,267

Qualified student loan bonds

Qualified hospital facilities

16

d

240

d

10

72

326

1,922

14

71

658

3,065

9

69

2,581

7,828

Qualified section 501(c)(3) nonhospital

bonds

All other bonds, combined [2]

0

60

0

585

d

0

d

0

d

0

d

0

0

0

0

0

d - Data deleted to avoid disclosure of information for specific bonds. However, the data are included in the appropriate totals.

[1] A given bond issue can include more than one purpose. Thus, the summation of number of issues by purpose will sometimes exceed the total number of issues. However, the

money amounts add to the totals.

146

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Table 10. New Money Long-Term Tax-Exempt Private Activity Bonds, by State of Issue and Selected

Bond Purpose, 2008

[Money amounts are in millions of dollars]

Selected bond purpose

State of issue

All States

Alabama

Alaska

Arizona

Arkansas

California

Colorado

Connecticut

Delaware

District of Columbia

Florida

Georgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Maryland

Massachusetts

Michigan

Minnesota

Mississippi

Missouri

Montana

Nebraska

Nevada

New Hampshire

New Jersey

New Mexico

New York

North Carolina

North Dakota

Ohio

Oklahoma

Oregon

Pennsylvania

Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

Vermont

Virginia

Washington

West Virginia

Wisconsin

Wyoming

U.S. Possessions [4]

Total [1]

Number

Amount

(1)

2,454

31

5

30

15

213

64

23

11

18

95

56

d

11

148

48

123

60

47

54

12

49

99

53

89

31

50

11

33

5

24

54

5

133

33

19

81

6

21

197

13

18

21

36

87

18

15

46

58

17

61

3

d

(2)

52,488

768

192

1,045

165

5,488

827

611

161

726

2,058

1,530

d

370

1,902

903

476

216

804

2,453

253

1,269

2,408

631

1,069

629

1,638

138

230

112

399

2,089

205

5,398

549

307

2,197

210

511

3,030

287

272

266

678

2,212

236

234

1,726

784

351

875

72

d

Airports, docks, and

wharves [2]

Water, sewage, and

solid waste disposal [2]

Qualified residential

rental

Number

Number

Number

(3)

46

d

0

d

0

d

d

0

d

0

8

d

0

0

d

d

0

0

d

d

0

0

0

d

d

0

0

0

0

0

0

0

0

d

d

0

0

0

0

0

d

0

0

0

6

0

0

d

5

0

0

0

0

Amount

(4)

2,097

d

0

d

0

d

d

0

d

0

384

d

0

0

d

d

0

0

d

d

0

0

0

d

d

0

0

0

0

0

0

0

0

d

d

0

0

0

0

0

d

0

0

0

90

0

0

d

128

0

0

0

0

(5)

88

4

0

4

0

16

0

0

0

0

d

d

0

0

d

5

d

0

d

d

0

d

d

d

d

0

d

0

d

0

0

d

0

d

d

0

6

0

d

4

0

3

d

0

17

0

0

d

d

d

0

0

0

Amount

(6)

2,575

145

0

43

0

451

0

0

0

0

d

d

0

0

d

232

d

0

d

d

0

d

d

d

d

0

d

0

d

0

0

d

0

d

d

0

125

0

d

252

0

86

d

0

618

0

0

d

d

d

0

0

0

(7)

312

0

0

d

0

97

d

d

d

d

22

7

d

0

11

3

d

d

5

3

d

11

6

0

8

3

d

d

0

d

d

d

d

25

d

0

12

0

7

d

0

3

0

9

12

0

4

7

14

d

d

0

d

Amount

(8)

4,573

0

0

d

0

1,158

d

d

d

d

195

88

d

0

156

33

d

d

36

35

d

113

98

0

42

17

d

d

0

d

d

d

d

1,031

d

0

73

0

27

d

0

41

0

41

143

0

4

79

137

d

d

0

d

Qualified Gulf Opportunity

Zone and Gulf Opportunity

Zone mortgage

Number

(9)

94

d

d

4

d

4

0

d

d

0

d

d

0

4

0

d

d

d

d

d

3

3

3

0

d

d

d

d

d

d

4

d

d

3

d

d

4

d

d

d

d

0

d

3

0

5

d

d

d

d

d

d

0

Amount

(10)

5,076

d

d

92

d

639

0

d

d

0

d

d

0

175

0

d

d

d

d

d

92

113

160

0

d

d

d

d

d

d

99

d

d

291

d

d

357

d

d

d

d

0

d

120

0

68

d

d

d

d

d

d

0

Footnotes at end of table.

147

Tax-Exempt Bonds, 2008

Statistics of Income Bulletin | Winter 2011

Table 10. New Money Long-Term Tax-Exempt Private Activity Bonds, by State of Issue and Selected

Bond Purpose, 2008—Continued

[Money amounts are in millions of dollars]

Selected bond purpose—continued

State of issue

All States

Alabama

Alaska

Arizona

Arkansas

California

Colorado

Connecticut

Delaware

District of Columbia

Florida

Georgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Maryland

Massachusetts

Michigan

Minnesota

Mississippi

Missouri

Montana

Nebraska

Nevada

New Hampshire

New Jersey

New Mexico

New York

North Carolina

North Dakota

Ohio

Oklahoma

Oregon

Pennsylvania

Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

Vermont

Virginia

Washington

West Virginia

Wisconsin

Wyoming

U.S. Possessions [4]

148

Qualified mortgage

Qualified small issue

Number

Amount

Number

(11)

512

5

0

d

3

d

10

0

d

0

11

6

0

0

76

6

81

44

5

d

d

d

14

13

9

d

18

0

17

d

d

11

0

10

3

d

6

d

d

62

d

d

10

3

5

d

3

4

12

0

20

0

0

(12)

1,270

28

0

d

7

d

14

0

d

0

53

26

0

0

76

27

16

45

38

d

d

d

48

75

16

d

56

0

11

d

d

44

0

41

18

d

36

d

d

165

d

d

19

17

41

d

8

15

18

0

74

0

0

(13)

14

0

0

0

0

0

d

0

0

0

0

0

0

0

0

0

0

0

d

0

d

0

d

0

d

0

d

0

0

0

0

d

d

0

0

0

0

0

0

0

d

0

0

0

d

d

d

0

0

0

0

0

0

Qualified hospital

Qualified section

501(c)(3) nonhospital

Amount

Number

Amount

Number

Amount

(14)

1,404

0

0

0

0

0

d

0

0

0

0

0

0

0

0

0

0

0

d

0

d

0

d

0

d

0

d

0

0

0

0

d

d

0

0

0

0

0

0

0

d

0

0

0

d

d

d

0

0

0

0

0

0

(15)

259

d

0

4

d

10

3

6

d

d

9

9

0

d

21

9

4

d

5

d

0

3

14

9

5

0

9

d

5

0

d

5

d

22

6

4

20

d

4

12

d

d

d

5

6

0

d

6

d

6

12

0

0

(16)

12,743

d

0

612

d

553

251

221

d

d

194

379

0

d

1,161

294

165

d

61

d

0

392

552

197

477

0

832

d

72

0

d

567

d

612

167

87

1,246

d

174

567

d

d

d

398

224

0

d

485

d

232

325

0

0

(17)

1,084

13

d

13

8

67

46

12

d

10

40

30

0

d

39

22

32

12

27

7

5

28

61

27

63

8

15

8

8

d

14

32

d

68

19

13

33

d

6

113

5

9

7

16

42

6

6

25

20

8

28

d

0

(18)

18,600

179

d

240

101

1,786

423

191

d

420

878

956

0

d

448

137

194

112

463

94

116

613

1,414

279

430

67

404

18

80

d

211

622

d

2,654

307

89

360

d

221

1,718

65

66

53

102

920

52

49

358

188

28

352

d

0

All other bonds,

combined [3]

Number

(19)

81

6

d

0

d

0

0

0

3

0

0

0

0

0

0

0

d

0

0

37

0

0

0

0

0

18

d

0

0

0

0

0

0

5

d

0

0

d

0

0

0

0

0

0

d

0

0

d

d

0

0

0

0

Amount

(20)

4,150

354

d

0

d

0

0

0

5

0

0

0

0

0

0

0

d

0

0

2,093

0

0

0

0

0

493

d

0

0

0

0

0

0

368

d

0

0

d

0

0

0

0

0

0

d

0

0

d

d

0

0

0

0

d—Data deleted to avoid disclosure of information about specific bonds. However, the data are included in the appropriate totals.

[1] A given bond issue can include more than one purpose. Thus, the summation of number of issues by purpose will sometimes exceed the total number of issues. However, the

money amounts add to the totals.

[2] For purposes of this table, certain bond purposes were combined. For this reason, data in this table will differ slightly from the data in Tables 7 and 9.

[3] For purposes of this table, this category includes all issues for which a specific purpose either did not apply or was not clearly indicated on the Form 8038, Informational Return for

Tax-Exempt Private Activity Bond Issues, as well as bonds issued for: local electricity or gas furnishing facilities, facilities issued under a transitional rule of the Tax Reform Act of

1986, qualified highway or surface freight transfer facilities, Gulf Opportunity Zone bonds, Gulf Opportunity Zone mortgage bonds, New York Liberty Zone bonds, qualified veterans'

mortgage bonds, nongovernmental output property bonds, and 2008 Housing Act bonds issued under IRC section 142 or 143.

[4] U.S. possessions include Puerto Rico, the U.S. Virgin Islands, Guam, and the Northern Mariana Islands.