Clients appreciate our ability to not only guide them through the full spectrum of public financing transactions, but also to help them navigate the sophisticated and often complex tax components that accompany them.
We have a dedicated team of tax attorneys and financial analysts who work diligently to stay 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) 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 rebate and yield restriction compliance including exceptions thereto
- 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
- Drafting post-bond issuance compliance policies and procedures
- Providing informal advice and private business activity analyses
- Preparing and presenting IRS private letter ruling requests
- Addressing post-issuance public finance noncompliance issues through the IRS Voluntary Closing Agreement Program
Clients benefit from the post-issuance compliance policies and procedures our team has developed relating to the proper use and timely expenditure of bond proceeds, use of bond-financed property, compliance with arbitrage rebate and yield restriction requirements, and the necessary documentation and record-keeping required by the IRS.
Arbitrage Compliance & Rebate Services
Beyond working with clients on navigating the general tax components of transactions, we also provide counsel on arbitrage rebate and yield restriction, managing the full spectrum of compliance and rebate liabilities. Recognizing that this space requires a sophisticated blend of the legal and financial worlds, we employ a team of financial analysts with CPA credentials who work closely with our attorneys to provide diligent, nuanced counsel to clients.