A Note from the Editors-in-Chief

In their article, the authors describe tax-exempt municipal debt securitization transactions and the tax issues associated with these transactions, including (1) whether the securitization vehicle is transparent from a federal income tax perspective and (2) whether the certificates representing ownership in the securitization vehicle will be respected as equity for tax purposes. The article continues with discussions, in the context of securitization vehicles that are treated as partnerships for federal income tax purposes, of (1) concerns that arise from hedging the risks of ownership of certain equity interests with total return swaps and (2) an elective, simplified federal income tax information reporting regime. [...]the article ends with a short discussion of state and local tax issues with respect to the securitization of the taxexempt municipal debt.