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Federal Tax - Structuring Transactions, Audits, Rebate, Post-Issuance Compliance

Structuring Transactions

Federal tax is one of the most complex areas in public finance. Our clients benefit from our decades of experience in structuring transactions in creative ways to help issuers meet capital financing needs. Whether working on a complex convention center or stadium project, a public power tenancy in common with its special rules, or the myriad of issues that arise when dealing with swaps or housing transactions, Ice Miller tax lawyers have been there and done that in billions of dollars of financings.   

IRS Audits

We are uniquely qualified to represent issuers and conduit borrowers before the Internal Revenue Service because our lawyers who practice in this area also have substantial experience negotiating and closing all types of financing transactions. Our experience in this area includes closing audits without penalty or fines, as well as negotiating settlement agreements. We maintain strong relationships with IRS agents across the country. Because of our reputation for working with the IRS effectively and efficiently, we are hired to provide counsel on IRS audits even when we did not participate in the original financing transaction.

Rebate and Post-Issuance Compliance

Ice Miller is the law firm best positioned to provide clients with crucial advice as to continuing compliance with federal tax requirements. We are one of very few law firms that provide rebate opinion and calculation services. Our rebate experience runs the gamut from the most straightforward single issue construction project which meets the six-month exception to complicated transactions with multiple series of parity bonds. In each case, Ice Miller provides a legal opinion as part of the calculation report. We regularly advise 501(c)(3) conduit borrowers as to post issuance compliance requirements such as the completion of Schedule K to IRS Form 990. All types of issuers and conduit borrowers rely on us to assist with private use monitoring.



Name Position Phone Email
Amy M. Corsaro Partner 317-236-2174
Tyler J. Kalachnik Partner 317-236-2116
David Nie Partner 317-236-2377
Philip C. Genetos Senior Counsel 317-236-2307
Susan Price Of Counsel 614-462-1106
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