Linda Schakel, former NABL President and partner at Ballard Spahr, testified on behalf of NABL at the October 28 Internal Revenue Service (IRS) hearing on the proposed issue price regulations published in June. Ms. Schakel reiterated the points made in NABL’s comments, which were submitted on September 22, particularly regarding the due diligence to be required of issuers.
NABL’s written comments are available here.