We have a dedicated team of tax attorneys and financial analysts who work with clients to address the tax components accompanying public finance transactions. We understand the nuances of the law and work with clients to address tax issues, while continuing to drive the project forward. Our team stays up-to-date on federal tax law developments that could impact our clients, and we have strong relationships with the United States Department of Treasury and the Internal Revenue Service (IRS) we draw on to assist clients.
While each client and transaction has unique tax components, we provide a number of “across-the board” services, including arbitrage and rebate compliance, representing clients in IRS bond audits, rendering formal special tax counsel opinions, including opinions required to sell or modify the use of bond-financed property, providing informal advice and private business activity analyses, preparing and presenting IRS private letter ruling requests, and addressing post-issuance public finance noncompliance issues through the IRS Voluntary Closing Agreement Program. We developed post-issuance compliance policies and procedures for clients to ensure the proper use and timely expenditure of bond proceeds, the proper use of bond-financed property, compliance with the arbitrage and rebate requirements, and the necessary documentation and record-keeping required by the IRS.
Navigating the federal tax laws governing public finance transactions requires legal counsel who sees the big picture. The complex and constantly-evolving laws and regulations present challenges that could impact transactions, and the ability to remain compliant can be the ultimate factor in the success of the project.