Webinar | 03.29.17 | 10am - 11am (Pacific Daylight Time)Online Webinar
On January 17, 2017, for the second time in 6 months, the IRS released updated guidance with respect to the safe harbor requirements for contracts for services performed in tax-exempt bond-financed facilities. Management contracts and other use agreements may give rise to private business use, which in the aggregate cannot exceed 10% per bond issue for governmental bonds and 5% per bond issue for qualified 501(c)(3) bonds. While these new revenue procedures are generally helpful, issuers and borrowers will need to carefully navigate these principle-based concepts to ensure that service contracts do not result in private business use.
Join BLX & Senior Tax Partners from Orrick on March 29th for a discussion regarding these new revenue procedures and how their application will impact the determination of private business use.
This 1 hour Webinar will take place on March 29th at 10 am PDT / 1 pm EDT.
Please register now to reserve your place. CPE and CLE credits will be offered.
CLE Credits Available: Y
Edwin Oswald, a partner in the Washington, D.C., office, is a member of the Tax Group. Ed's practice concentrates in the taxation of municipal finance including healthcare, charter schools, public power, higher education and non-profit issues, housing financing, airports and refinancings.
His practice also includes advising on post-issuance tax compliance matters including working with non-profit borrowers of tax-exempt bonds on new IRS Schedule K annual reporting matters.
He served in the Office of Tax Legislative Counsel at U.S .Treasury Department, where he developed policy, legislative initiatives and regulations affecting public finance and structured finance.
Los Angeles; Houston
Larry Sobel, is a tax partner in the Los Angeles and Houston offices. Larry has more than 35 years of experience in federal tax laws and regulations relating to all types of tax-exempt financings, particularly public power, private activity bonds such as airport facilities, colleges and universities and hospitals and exempt organizations and advance refundings issues.
As both bond counsel and underwriter’s counsel, he has been responsible for
structuring and analyzing the tax aspects of many tax-exempt financings
throughout the country.
Larry has extensive experience in handling IRS audits of bond transactions. He has represented issuers in dozens of audits all of which have ended favorably either with the IRS issuing a “no change” letter or by negotiating a reasonable settlement when needed. Larry also has handled a number of submissions under the IRS’ Voluntary Closing Agreement Program (or VCAP). The two most recent VCAP submissions represented cases of first impression for the IRS; one involving an issue of qualified energy conservation bonds relating to determining the amount of those bonds eligible for the federal subsidy; the other involved the plan to convert a “new money” bond issue into an advance refunding (which did not meet all of the requirements for a tax-exempt advance refunding). Both cases ultimately were resolved on the original terms proposed to the IRS.
Larry has also been instrumental in developing new financing techniques and structures. He first devised the tax structure and analysis for, and has served as tax counsel on, Orrick’s tax exempt tobacco revenue securitizations. He has developed the tax structure on numerous tax-exempt prepayments for natural gas for municipal utilities both within and outside of California.