Tax Counsel: Specialized Tax Counsel Services relating to the federal Tax Code. (a) Provide specialized legal advice regarding the IRS Code as it applies to the Agency's Single family and multifamily bond financing activities and to the programs funded with the proceeds of bonds, particularly with respect to the structure of proposed new issues of bonds and the structure and operation of the new programs relating to such bonds. (b) Provide required tax opinions evidencing compliance of each new issue of bonds with applicable provision of the IRS Code, and the adequacy of program documents and operating procedures/policies of the Agency to reasonably assure compliance with such Code provisions including, among others, Targeted Area designations, borrower income limitations and home sale price limitations. (c) Review and approve the detailed procedures to be followed by the Agency in calculating the Bond Yield and the Mortgage Yield associated with each new issue of bonds and each new bond-financed loan program.
