Larry Sobel Partner, 稅務
Los Angeles; Houston
Los Angeles; Houston
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.
Los Angeles; Houston
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.
Los Angeles
Los Angeles
Winnie has addressed the Bond Attorneys' Workshop for the National Association of Bond Lawyers relating to various topics, including arbitrage and rebate, refundings, working capital financings, and 501c3 financings. Winnie earned a J.D. in 1994 from the University of California, Davis School of the Law, where she was elected to the Order of the Coif and was a member of Law Review. She received her B.A. from Pitzer College.
Los Angeles
Los Angeles
Winnie has addressed the Bond Attorneys' Workshop for the National Association of Bond Lawyers relating to various topics, including arbitrage and rebate, refundings, working capital financings, and 501c3 financings. Winnie earned a J.D. in 1994 from the University of California, Davis School of the Law, where she was elected to the Order of the Coif and was a member of Law Review. She received her B.A. from Pitzer College.
Los Angeles
Ashley represents issuers, underwriters, servicers, lenders, and other market participants in connection with securitizations, asset financings and sales, and negotiation of lending facilities. Ashley's practice encompasses a variety of asset-backed securities, including residential mortgage-backed securities and credit and charge card receivables.
Los Angeles
Ashley represents issuers, underwriters, servicers, lenders, and other market participants in connection with securitizations, asset financings and sales, and negotiation of lending facilities. Ashley's practice encompasses a variety of asset-backed securities, including residential mortgage-backed securities and credit and charge card receivables.
Washington, D.C.
Washington, D.C.
His public finance practice includes representation of issuers or underwriters in long-term and short-term general obligation and revenue bond financings for municipalities, charter schools, educational facilities, and water and power authorities and advising clients on economic development incentives.
Before joining Orrick, Darrin was counsel within the Public Finance Group at Hunton & Williams LLP. He also has served as chairman, director or member of several boards and commissions including:
Washington, D.C.
Washington, D.C.
His public finance practice includes representation of issuers or underwriters in long-term and short-term general obligation and revenue bond financings for municipalities, charter schools, educational facilities, and water and power authorities and advising clients on economic development incentives.
Before joining Orrick, Darrin was counsel within the Public Finance Group at Hunton & Williams LLP. He also has served as chairman, director or member of several boards and commissions including:
Los Angeles
She advises opportunity, investment and private equity funds, institutional investors and developers on commercial real estate transactions including joint venture structuring, financing, development, acquisitions, sales, lease agreements, and other corporate real estate activities. Taylor is familiar with structuring and drafting corporate organizational agreements, financing, acquisition and disposition documents. She has experience with a variety of asset types, including commercial, mixed-use and residential properties. Further, she regularly advises startups, growth stage companies and not-for-profit organizations on their leasing transactions.
Los Angeles
She advises opportunity, investment and private equity funds, institutional investors and developers on commercial real estate transactions including joint venture structuring, financing, development, acquisitions, sales, lease agreements, and other corporate real estate activities. Taylor is familiar with structuring and drafting corporate organizational agreements, financing, acquisition and disposition documents. She has experience with a variety of asset types, including commercial, mixed-use and residential properties. Further, she regularly advises startups, growth stage companies and not-for-profit organizations on their leasing transactions.
New York
New York