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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.
Washington, D.C.
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.
洛杉矶; 休斯敦
洛杉矶; 休斯敦
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.