People

Barbara Jane League Partner

Houston; Austin

Barbara represents state and local governmental, nonprofit and for-profit corporations, and other market participants in the issuance of qualified 501(c)(3) private activity bonds for eligible residential rental projects for affordable and middle-income housing, as well as related infrastructure financing, including tax and revenue anticipation notes (TRANs). She serves as special tax counsel to one of the largest sports authorities in Texas, with the goal to promote local and community development, including maintenance and expansion of the city’s stadiums and parks.  

She also has significant experience representing nonprofit organizations. Formerly an attorney with the Chief Counsel of the Internal Revenue Service, Barbara has represented clients before the IRS in a variety of matters involving tax-exempt bonds, including audits and private letter ruling requests. She has participated in all facets of the tax analysis associated with the issuance of governmental purpose bonds, certain tax credit bonds, qualified 501(c)(3) bonds, qualified residential rental bonds and qualified small issue bonds.

Barbara has served on the Steering Committee and has chaired the Working Capital panel and the Bond Direct Purchase - Advanced Tax Topics panel for the Bond Attorneys’ Workshop, the oldest and largest annual gathering of bond lawyers.

Mayling Leong Of Counsel

Sacramento

In addition, Mayling serves as issuer’s counsel to the California Statewide Communities Development Authority and the California Public Finance Authority for 501(c)(3) conduit financings, and as special counsel to the California State Treasurer’s Office in transactions for bonds insured through the California Department of Health Care Access and Information’s Cal-Mortgage Loan Insurance program.

Jenna Magan Partner

Sacramento

Jenna has worked on all structures available in public finance, including fixed and variable, tax-exempt and taxable, insured, letter of credit and liquidity supported bonds, conversions, tenders, exchanges, restructurings and reofferings, senior/subordinate, capital appreciation and convertible capital appreciation bonds, securitizations, project finance, direct purchases, bank-qualified transactions and 144A and Section 4a2 offerings.

Jenna's practice focuses on the following areas, in which she has acted as bond, borrower’s, disclosure, underwriter's, and bank/direct purchaser’s counsel:

• Healthcare, Senior Living and Other 501(c)(3) Financings
• Local Government Lease, Enterprise (Water, Wastewater, Airport, Solid Waste), Pension Obligation and Short-Term Financings
• State of California Bond Financings
• Project Financings
• Tobacco Securitization Financings
• Post-Issuance Compliance

Richard J. Moore Partner

San Francisco

Prioritizing the importance of client relationships and formulating viable solutions tailored to each client’s unique strategic goals, Rich works extensively in the healthcare, energy prepay and public utilities and affordable housing housing sectors. He serves as the lead tax attorney on dozens of transactions each year. This substantial deal volume has given Rich experience with myriad complex and unique tax issues associated with such transactions and allows him to provide clients with practical guidance and market-tested advice.

Healthcare: Rich has focused on healthcare transactions for over two decades. Clients range from large systems such as Kaiser and Sutter to single-site hospitals. Deals include multibillion green bond deals to finance environmentally friendly improvements, complex acquisition financing deals, workout deals for financially distressed systems, smaller equipment financing deals, and everything between.

Energy Prepay and Public Utilities: Rich has served as tax counsel on many gas and electricity prepayment transactions for clients which include Black Belt Energy District and Southeast Energy Authority. Rich has worked with the Bonneville Power Administration and a California Electric Utility Company for over 20 years on a range of financing programs primarily aimed at financing and refinancing Bonneville’s nuclear generating resource and the California Electric Utility Company's generation, distribution, and transmission facilities. In addition, Rich has an extensive history working on deals for the San Diego County Water Authority and the San Francisco Public Utilities Commission.

Affordable Housing: Rich focuses on the tax-exempt financing of all types of housing projects, including 100% affordable projects that combine tax-exempt bonds with low-income housing tax credits, workforce housing projects that cater to middle income tenants, and mixed income housing.

Aside from transactional work, Rich is also an advocate, representing governmental issuers, conduit borrowers, and investment banks in IRS and other regulatory proceedings, including tax-exempt bond audits, voluntary closing agreement program (VCAP) requests, and requests for private letter rulings. Rich has successfully closed IRS examinations relating to multifamily housing, healthcare, solid waste, and arbitrage matters. He has been involved in numerous regulatory and legislative projects and has found that a strong working relationship with IRS and Treasury Department personnel facilitates obtaining good results.

Rich served on the Board of Directors of the National Association of Bond Lawyers (NABL) from 2011 to 2021 and, in 2019-20, was President of NABL. Rich has written and lectured extensively on the tax aspects of public finance transactions, having served as editor of the Federal Taxation of Municipal Bonds Deskbook, chaired the National Association of Bond Lawyers Bond Attorneys Workshop, and served on several other panels at industry seminars and roundtables. Rich became a fellow of the American College of Bond Counsel in 2018.

Thomas Myers Senior Counsel

New York

Tom's practice also focuses on financings for industrial development bonds, local development corporations, housing bonds, resource recovery and water/sewer authority revenue bonds. He has extensive experience as underwriter’s and placement agent’s counsel on a wide variety of public finance matters. In addition, Tom was special counsel in connection with tax lien and tobacco settlement securitizations by various New York counties.

Edwin Oswald Partner

Washington, D.C.

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.

Ed Oswald is the author of "From Ronald to Donald: How the Myth of Reagan Became the Cult of Trump." In this book, he explores the tax policy behind “supply side economics” and the transformation of conservative politics from Ronald Reagan’s presidency to Donald Trump’s rise. Ed is frequently sought after for his expertise and is quoted by top publications, including Newsweek and The Bond Buyer.

Christine Reynolds Partner

Portland; Seattle

Christine has more than two decades of experience in public infrastructure finance, advising on both traditional bond financings and innovative funding structures. She serves as a Vice-Chair of the Public Finance Group and on the leadership team for the Impact Finance Group.

Christine’s experience includes various general obligation and revenue bond financings, including those relating to transportation, education, healthcare, water and wastewater, economic development, urban renewal, public power and other complex and innovative social and infrastructure financings sometimes involving public-private partnerships (P3) for large transportation and utility issuers, state and local municipalities, and other for-profit and nonprofit corporations.

She has extensive knowledge and experience with disclosure requirements for municipal issuers under federal securities laws, including both initial and continuing disclosure issues, material events disclosure, public offerings, private placements and other municipal securities regulatory matters.

Christine is a frequent speaker at conferences and seminars given by trade and professional organizations within the municipal finance industry, including serving as Chair for The Bond Buyer's 2022 Infrastructure Conference and Board of Directors to Women in Public Finance.

Justin B. Rosas Managing Associate

Austin

Justin’s practice focuses on public finance, which includes the representation of local government entities, including: state agencies, municipalities, school districts, and special districts; non-profit organizations; and financial institutions that serve as underwriters to municipal bonds. Prior to joining Orrick, Justin represented and counseled government entities and private corporations in litigation matters. 

Michael E. Schrader Partner

Portland

Mike also represents banks and underwriters in connection with the purchase and sale of bonds and other financing and credit-related matters.

A significant portion of Mike’s practice is devoted to private activity bond financings. This includes representing Oregon Housing and Community Services and Oregon Facilities Authority in connection with their conduit revenue bond programs. Over the course of his more than 20 years as a bond attorney in Oregon, he has competed dozens of project financings throughout the State with a variety of public and private sponsors, developers and funders.

Mike received the Firm's Community Responsibility Award in 2011 in recognition of his community service and pro bono work. He currently serves on the Boards of Bridge Meadows, a developer, owner and operator of affordable intergenerational housing communities, and the Portland Housing Center, an organization providing educational and financial services to promote homeownership in underserved communities. He also serves as special counsel (pro bono) to Mercy Corps in connection with its Community Investment Trust (CIT) Program.

Before joining Orrick, Mike was a partner at Ater Wynne LLP in Portland. Prior to that, Mike was an associate at Ice Miller in Indianapolis, Indiana.

Larry Sobel Partner

Los Angeles; Houston

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.

Amanda Stephens Partner

Austin; Houston

Amanda has advised on more than $5 billion of both publicly-offered and privately-placed charter school financings. Her work on these financings extends across the country, including Texas, Florida, Tennessee, California, Arizona and New York, among many others. Amanda works with a first-of-its-kind nonprofit social impact fund that leverages private charter loans to the public market. Since their creation in 2018, Amanda has worked on documenting more than $1.7 billion in loans to high-performing charter schools who do not otherwise have access to long term, low cost financing. Amanda and team are tasked with working with the local borrower’s counsel for each new borrower and each new state to create a financing structure that meets the long term needs of the borrower, while conforming with state charter law and the clients lending requirements. Amanda has also created structures to help with taxable refundings, to finance around existing new market tax credit structures and many other needs of the borrowers. 

Amanda also represents banks and other financial institutions in connection with direct purchases of tax-exempt bonds and the issuance of letters of credit and other liquidity facilities in connection with tax-exempt transactions. 

Over the course of her career, Amanda has prepared, negotiated and reviewed contracts, loan documents, amendments, closing documents, default letters, demand letters, payoff and buyout agreements, intercreditor subordination agreements, and federal tax lien subordinations. She also has reviewed client contracts and MSA agreements in the oil and gas, construction, medical, retail and transportation industries, and she has addressed regulatory and compliance issues for the finance industry and oil and gas industry. Amanda previously served as an in-house attorney for a national financial services company. She also has served as a staff attorney for Judge Jaclanel McFarland of the 133rd Civil District Court in Harris County, Texas, and as assistant district attorney for the Harris County District Attorney’s office.