Richard J. Moore


San Francisco

Rich Moore is an accomplished Tax partner resident in Orrick's  San Francisco office.

Rich works extensively in the healthcare and multifamily housing areas, and invariably serves as the lead tax attorney on dozens of these deals with an aggregate par amount in excess of ten billion dollars each year. This volume of deals enables Rich to encounter the regular and complex tax issues associated with such transactions, and have insight into viable solutions to such issues. Rich also concentrates his practice in deals for water utilities, public power including gas and electricity prepay transactions, solid waste disposal facilities, municipal derivatives, and arbitrage matters. He has served as bond counsel, underwriter's counsel, borrower's counsel, and special tax counsel in a wide variety of public finance transactions.

As an advocate, Rich has represented governmental issuers, conduit borrowers, and investment banks in IRS proceedings, including tax-exempt bond audits, voluntary compliance (VCAP) requests, and requests for private letter rulings. Specifically, in 2017 and 2018, Rich was the lead representative on dozens of audits of multifamily housing bond deals, each of which successfully closed. Additionally, Rich has successfully closed IRS examinations relating to healthcare, solid waste, and arbitrage matters. Rich has also 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 has served on the Board of Directors of the National Association of Bond Lawyers (NABL) since 2011 and, in 2018, was elected 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.

    • Lead tax lawyer to the California Health Facilities Financing Authority for Kaiser Permanente's $4.2 billion bond sale. The transaction represented the largest aggregate financing by a 501(c)(3) healthcare institution, the largest taxable issuance by a 501(c)(3) healthcare institution, and the largest Green Bond issuance by any healthcare organization.  (2017 Bond Buyer National and Healthcare Deal of the Year).
    • Bond Counsel to the Pinal County Industrial Development Authority for its issuance of $61.3 million of Environmental Facilities Revenue Bonds (Green Bonds). The proceeds of the bonds were used to develop and construct an anaerobic digestion facility in Stansfield Arizona for the creation of renewable natural gas from dairy manure and food waste.
    • Lead tax lawyer on various California Pollution Control Financing Authority solid waste transactions for more than a decade; and
    • Lead tax lawyer on various California Housing Finance Authority transactions for more than a decade.