Public Finance Tax
Butler Snow’s highly skilled public finance tax team specializes in complex tax matters pertaining to tax-exempt and tax-advantaged bonds. Our tax lawyers have collectively participated in nearly every type of authorized municipal financing transaction and have the skills to navigate our clients through the myriad of tax issues presented in tax-exempt and tax-advantaged bond financings to ensure compliance with the Internal Revenue Code.
The firm’s public finance tax practice encompasses a broad range of matters including:
Public Finance Tax
Our team structures tax-exempt and tax-advantaged financings. Our attorneys work closely with issuers, conduit borrowers and other law firms serving as special tax counsel, providing tax assistance in the structuring of various municipal financing transactions and providing advice to bond counsel firms who need additional tax support. We represent issuers and conduit borrowers before the IRS in both random and targeted audits where the tax-exempt status of the bonds is under scrutiny by the IRS. Our lawyers work with the United States Department of Treasury and the Internal Revenue Service when preparing, presenting and obtaining IRS private letter rulings on complex tax matters on behalf of our clients. Our group provides a wide variety of arbitrage and rebate-related services to assist our clients in complying with the complex arbitrage and rebate requirements set forth in the Internal Revenue Code and the Income Tax Regulations. Our tax lawyers also perform complex private business use and private payment tracking analysis to assist our clients in their post-issuance compliance efforts.
With respect to governmental bond issues and conduit bond issues, our group provides comprehensive services to these issuers regarding arbitrage rebate analysis and reports, regulations involving investment of bond proceeds, use of debt financed property, sources of payment for bond debt service, and maintenance of special records relating to guaranteed investment contracts and interest rate swaps. We represent clients in audits before the Internal Revenue Service and state regulatory bodies involving a wide variety of public finance issues. In the resolution of post-issuance compliance matters, we are experienced in the reallocation of bond proceeds, remedial actions under the change in use rules, and closing agreements with the Internal Revenue Service.