IRS Revenue Procedure 2017-13 Safe Harbor Requirements for Services Contracts
He also has legal expertise relating to both charter schools and the federal income tax classification of governmental and quasi-governmental entities. He has consulted on thousands of tax-exempt, build America and tax credit bond issues and has developed deep expertise in almost every tax aspect of municipal finance. Private activity bonds for multifamily housing, solid waste, charter schools and independent schools are areas of particular focus in his practice, as are higher education, short-term and long-term working capital and the various forms of pooled financings. Chas also has advised numerous clients experiencing financial distress or bankruptcy in tax matters relating to their municipal bonds. Representative active clients include the State of California, the University of California, the Bay Area Toll Authority, and Charter School Capital.
As a legal and policy advocate, Chas represents both government and non-government clients in federal tax rulemaking matters and in IRS proceedings, including the various types of tax-exempt bond audits, voluntary compliance (VCAP) requests and requests for private letter rulings. He has successfully closed IRS examinations relating to solid waste, water and wastewater, working capital, healthcare, pooled, multifamily housing, and industrial development bond financings. He has obtained multiple private letter rulings and technical advice memoranda and has been integrally involved in numerous regulation and legislative projects. He has found that a close working relationship with IRS and Treasury Department personnel often is critical to obtaining good results for clients.
Chas is a regular panelist at industry and bar association seminars on public finance tax topics (most recently on the topics of working capital financing and IRS enforcement) and has lectured to the IRS at their field agent training program.
Some recent representations include the following.
Representative List of Active Clients
Representative List of Transactions
Bond and tax counsel engagements for large municipal issuers: (1) lead tax lawyer on all California General Obligation Bonds since 2007, (2) lead tax lawyer on all University of California General Revenue Bonds, Limited Project Revenue Bonds and Medical Center Pooled Revenue Bonds, and (3) lead tax lawyer on all Bay Area Toll Authority Toll Bridge Revenue Bonds.
Bond and tax counsel engagements for pooled financings: (1) lead tax lawyer on all California Infrastructure and Economic Development Bank Infrastructure State Revolving Fund Revenue Bonds and (2) lead tax counsel on the California School Cash Reserve Program Authority’s annual pooled financing and cross fiscal year pooled financings.
Bond and tax counsel engagements for long-term working capital financings: (1) lead tax lawyer on State of California Economic Recovery Bonds, (2) lead tax lawyer on Orange County Public Financing Authority Lease Revenue Refunding Bonds, Series 2005, and (3) lead tax counsel on California Infrastructure and Economic Development Bank State School Fund Apportionment Lease Revenue Bonds.
Financing engagements for public charter schools: (1) lead outside counsel for Charter School Capital receivables purchase program (operating in numerous States), (2) lead tax lawyer on Industrial Development Authority of the County of Pima Educational Facility Revenue Bonds (New Plan Learning, Inc. Project), Series 2011A, and (3) lead tax lawyer on California School Finance Authority Educational Facilities Revenue Bond transactions.
Bond and tax counsel engagements for solid waste financings: (1) lead tax lawyer on various California Pollution Control Financing Authority transactions since 1995 and (2) special tax counsel on Sanger Texas Industrial Development Corporation Industrial Development Revenue Bonds, (Texas Pellets Project) and Louisiana Public Facilities Authority Solid Waste Disposal Facility Revenue Bonds (Louisiana Pellets, Inc., Project).