Tax Partner Discusses Changes to Issue Price Rules

The Bond Buyer
March.28.2014

Tax partner Chas Cardall participated on a panel at the National Association of Bond Lawyers' Tax and Securities Law Institute on the changes to issue price rules.

Cardall stated that “bond lawyers need to be realistic and acknowledge that there will be changes to the existing issue price rules. We're just not putting the toothpaste back in the tube. It's just not happening. I think as soon as all of us are sort of more realistic about where this is going, maybe we have a better conversation."

Cardall added that the purpose of the panel was to talk more broadly about the issue price question and hear the perspectives of the regulators and enforcers. The hope was to get a sense of how market participants and regulators may be able to move toward a compromise, he said.

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Charles C. Cardall Partner, Tax

San Francisco

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Charles C. Cardall Partner

San Francisco

He also has legal experience 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 knowledge 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.