26 CFR §1.141-14

1. (a)Authority of Commissioner to reflect substance of transactions. If an issuer enters into a transaction or series of transactions with respect to one or more issues with a principal purpose of transferring to nongovernmental persons (other than as members of the general public) significant benefits of tax-exempt financing in a manner that is inconsistent with the purposes of section 141, the Commissioner may take any action to reflect the substance of the transaction or series of transactions, including—
   1. (1)Treating separate issues as a single issue for purposes of the private activity bond tests;
   2. (2)Reallocating proceeds to expenditures, property, use, or bonds;
   3. (3)Reallocating payments to use or proceeds;
   4. (4)Measuring private business use on a basis that reasonably reflects the economic benefit in a manner different than as provided in § 1.141-3(g); and
   5. (5)Measuring private payments or security on a basis that reasonably reflects the economic substance in a manner different than as provided in § 1.141-4.
2. (b)Examples. The following examples illustrate the application of this section: