Tax Compliance and Audit

Navigating the constantly-evolving federal tax laws that impact public finance transactions requires legal counsel who can see the big picture while still managing the nuances of the law. Nearly every public financing transaction requires the attention of tax attorneys familiar with these laws. In addition to our teams of attorneys, we also employ full-time financial analysts who are dedicated to providing tax support services to clients, ensuring that we are capable of handling a transaction of any size.

Our tax team stays abreast of federal tax law developments that could impact our clients, and we have built strong relationships with the United States Department of Treasury and the Internal Revenue Service that 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, providing informal advice and private business activity analyses, preparing and presenting IRS private letter ruling requests, and addressing post-issuance public finance issues through the IRS Voluntary Closing Agreement Program. We also have developed a post-issuance compliance program 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.

Highlights