OpenChainGraph Suite · ART-569 · Municipal Finance & Tax-Exempt Bonds

Muni Arbitrage Spending-Exception Checker

Tests whether a tax-exempt bond issue's declared expenditure schedule satisfies the IRC section 148 / Treas. Reg. 1.148-7 6-month, 18-month, or 24-month spending exception, including the reasonable-retainage variant of each schedule and a caller-declared de minimis amount. Each milestone gets its own verdict; the full exception status rolls those up.

Spending exceptions only · not the rebate computation Reasonable retainage & de minimis are declared, never assumed Verdict per milestone: MET · FAILED · PENDING

🔒 All inputs are processed locally in your browser. No data is transmitted. Do not enter real personal data — use synthetic or anonymised inputs only.

⚠ Not tax advice. This tool tests only the spending-exception milestone schedules in Treas. Reg. section 1.148-7 against the expenditure schedule you supply; it does not compute the future-value arbitrage rebate, and satisfying a milestone here means only what the cited regulation says it means. Confirm current text and facts with qualified bond counsel.

Issue & election

The demo values below are synthetic and already loaded, so you can press Run without entering anything of your own.

Issue date

Evaluation (as-of) date

Gross proceeds (minor units)

Elected exception

Reasonable retainage elected

De minimis (minor units, optional, capped at lesser of 3% of gross proceeds or $150,000)

Expenditure schedule (JSON array: date, amount_minor, description)

Milestones

Rejected inputs

Execution Hash (SHA-256)

What this does not do

It does not compute the future-value arbitrage rebate liability, which is a deliberately separate, not-yet-built tool. It does not determine whether a particular expenditure qualifies as a capital expenditure of the issue, does not source or verify any expenditure against a bank record or draw request, and is not legal or tax advice. A MET result means only that the declared expenditure schedule satisfies the cited milestone percentages as of the declared evaluation date.

ART-566 and ART-568 are the other recompute-the-counterparty's-number nodes in this wave: this one is the municipal-finance case, testing IRC section 148 spending-exception milestones rather than a three-way balance close or a securitization waterfall.