# Tax-Exempt Bonds, 2008

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## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

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.

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A2c0edb4aa6e0a2ab. Public record. Not legal advice.