Dean Criddle
Of Counsel
San Francisco
Dean E. Criddle, a senior counsel in the San Francisco office, is a member of the Tax Group. Concentrating his practice in electric and gas utility finance, Dean serves as both tax and finance counsel to utilities, underwriters, financial advisors, special purpose issuers, developers and state public utilities commissions in utility financings.
His broad experience ranges from “stranded cost” securitization financings for investor-owned electric utilities to tax-exempt financings for utilities owned by investor-owned companies, nonprofit corporations, states, local governments and federal power marketing agencies.
Dean has advised Bonneville Power Administration in connection with its efforts to refinance and extend the maturities of a portfolio of approximately $6 billion of tax-exempt and taxable notes and bonds issued for its benefit by Energy Northwest (formerly known as Washington Public Power Supply System).
In addition to working on transaction-specific capital markets matters, Mr. Criddle provides ongoing tax, regulatory and general business law advice to a variety of clients, including:
- Bonneville Power Administration
- Pacific Gas and Electric Company
- California Independent System Operator Corporation
- Public Utility District No. 1 of Snohomish County, Washington
- Public Utility District No. 1 of Chelan County, Washington
- Florida Public Service Commission
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He has obtained more than 20 private letter rulings from the IRS on matters ranging from the tax treatment of securitized bonds issued to refinance stranded cost of electric utilities, to confirming that proposed activities of nonprofit corporations will not adversely affect their tax-exempt status under Section 501(c)(3) of the Internal Revenue Code. He also regularly represents clients in IRS audits. In addition, over active opposition from the IRS, Dean has obtained declaratory judgments from the United States Tax Court in a case confirming the tax-exempt status of bonds (California Health Facilities Authority v. Commissioner of Internal Revenue, 90 T.C. 832 (1988)), and in a case confirming that a nonprofit Section 501(c)(3) organization need not be classified as a “private foundation” (Friends of the Society of Servants of God v. Commissioner of Internal Revenue, 5 T.C. 209 (1980)).
