IRS Audits of Tax-Exempt Bonds: What To Do When the IRS Comes Knocking at Your Door

July.23.2014

This informative webinar is designed to introduce governmental issuers and for-profit or non-profit borrowers of tax-exempt debt and other interested parties (such as current and prospective investors, financial advisors, underwriters) to the IRS tax-exempt bond audit process.

This program will not be limited to a basic introduction of IRS bond audits, but will cover a detailed description of the entire IRS examination process and practical advice regarding steps to be taken and pitfalls to be avoided.

This webinar will focus on:

The IRS Process for Selecting a Bond Issue for Examination
Information Document Request (IDR)-what is the IRS looking for and how to respond
Settlement Standards and Process
Voluntary Compliance Agreement Program (VCAP)

Authors

Larry Sobel Partner, Fiscalité

Los Angeles; Houston

See my bio

D:+1 213 612 2421
E: [email protected]

Practice:

Finance Sector
Fiscalité

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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.

Richard Chirls Partner, Fiscalité

New York

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D:+1 212 506 5250
E: [email protected]

Practice:

Finance Sector
Fiscalité

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See full bio

Richard Chirls Partner

New York

With more than 30 years of experience, Richard is widely recognized as one of the nation’s foremost authorities, having broad experience with tax exempt financings and related transactions involving governmental and not-for-profit entities. His skill and stature in the public finance community was recognized by the National Association of Bond Lawyers’ highest award for his career of distinguished service in public finance.

Richard focuses on new products, including the development of new and creative financing techniques for governments, non-profits and investment bankers. He regularly works on transactions throughout the country. However, in his home office in New York City, he leads the relationship with the Port Authority of New York and New Jersey, serving as counsel on well over 100 transactions over a period of more than 20 years and has headed the tax work in connection with every financing of a cultural facility relating to museums and performing arts in New York City over this same period. Richard has worked on the tax aspects of several of the largest and most complex public private partnership (P3) transactions in recent years. He frequently acts as special tax counsel to issuers and underwriters of municipal finance issues.