Comment from American Bar Association Tax Section

Summary: The American Bar Association Section of Taxation opposes the Proposed Regulation, arguing that it is not a clarification but a new, restrictive rule that contradicts the legislative intent of Section 148. They contend that the proposal imposes unnecessary administrative burdens, conflicts with existing rules under sections 141, 142, and 147, and hinders the efficient financing of complex projects by requiring funds to be on hand at the exact time of expenditure.