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Amy represents all types of governmental clients, including state and municipal entities, as well as conduit borrowers, to provide counsel on Section 103 tax issues, including assistance with structuring transactions, IRS audits, private use calculations, and arbitrage rebate compliance. Amy understands that officials and staff of governmental entities are busy meeting the needs of taxpayers, and that conduit borrowers are focused on running businesses. She endeavors to make the process of issuing tax-advantaged bonds easier for clients, cognizant that issuing tax-advantaged bonds is not something these clients do every day.

Because she spent the first 10 years of her career serving as bond counsel in a variety of tax-advantaged bonds transactions before changing her focus to Section 103 tax issues, Amy understands what it takes to get a transaction to closing. Her knowledge of the tax rules related to tax-advantaged bond issues allows her to provide quick and succinct counsel when clients are racing against the clock to structure a transaction and get a bond issue to market—whether the transaction is for a new money construction project or a refunding of an outstanding bond issue. Amy’s explanations of complicated federal tax rules to clients are easy to understand and put them at ease when facing stressful inquiries from the IRS.

Clients appreciate Amy’s ability to advise on the many aspects of post-issuance compliance for bond issues, such as the rules related to arbitrage rebate spending exceptions and helping 501(c)(3) clients complete Schedule K to Form 990. Her goal is to make post issuance-compliance as painless as possible for those she serves.
Reported and Representative Cases
  • Amy regularly advises large and small issuers of tax-exempt bonds as to compliance with post-issuance federal tax requirements.
Representative Transactions
  • In the arbitrage rebate area, Amy performs rebate analysis and reviews rebate calculations for numerous clients each year.
Firm Publications
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