Webinar: Current Thinking on Advance Refunding Alternatives

The Bond Buyer
April.02.2020

It has been two years since advance refundings were eliminated by the 2018 Tax Act. During that time a number of different structures have been proposed, including some that were designed as an attempt to mirror the economics that advance refundings previously provided. In this on-demand web seminar, Barbara Jane League and Larry Sobel, tax partners at Orrick Herrington & Sutcliffe LLP, discuss the status of advance refunding alternatives, including the elusive Cinderella bond structure.

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Speakers

Barbara Jane League 合伙人, Public Finance, 税务

休斯敦; Austin

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D:+1 713 658 6786
E: [email protected]

Practice:

Finance Sector
Public Finance
税务

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Barbara Jane League 合伙人

休斯敦; Austin

She also has significant experience representing nonprofit organizations. Formerly an attorney with the Chief Counsel of the Internal Revenue Service, Barbara has represented clients before the IRS in a variety of matters involving tax-exempt bonds, including audits and private letter ruling requests. She has participated in all facets of the tax analysis associated with the issuance of governmental purpose bonds, certain tax credit bonds, qualified 501(c)(3) bonds, qualified residential rental bonds and qualified small issue bonds.

Barbara has served on the Steering Committee and has chaired the Working Capital panel and the Bond Direct Purchase - Advanced Tax Topics panel for the Bond Attorneys’ Workshop, the oldest and largest annual gathering of bond lawyers.

Larry Sobel 合伙人, 税务

洛杉矶; 休斯敦

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

Practice:

Finance Sector
税务

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Larry Sobel 合伙人

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.