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About Victoria

Victoria Ozimek offers legal advice to clients regarding all aspects of tax advantaged obligations, from vetting the tax issues on proposed financing structures to assisting issuers with post-issuance compliance matters such as remedial actions and private business use analyses. She has also acted as special tax counsel to a number of issuers in situations where an issuer’s regular counsel may not be in a position to provide the specific tax expertise needed. Victoria has assisted issuers with responding to examinations of obligations by the Internal Revenue Service (IRS) and, if necessary, negotiating with the IRS regarding any identified issues. She has also advised issuers regarding the IRS’s Voluntary Closing Agreement Program.  

When needed, Victoria has worked with clients to secure private letter rulings and other guidance from the IRS regarding the tax effect of a proposed action. Victoria consistently seeks to provide issuers with the tools needed to successfully manage the requirements imposed by federal tax law by utilizing tax due diligence process as means to communicate with issuers regarding their compliance obligations and regularly seeking opportunities to educate the financing team regarding recent developments. She is very involved with the National Association of Bond Lawyers, and is a frequent speaker on tax matters with respect to tax advantaged debt.                               

Experience

Recent Notable Matters

Cypress-Fairbanks Independent School District — tax counsel to issuer in connection with $446.1 million of Unlimited Tax School Building and Refunding Bonds, Series 2016

Texas river authority — received a favorable private letter ruling regarding the allocation of governmental and exempt facility bonds to expenditures for costs of projects for various issuer facilities

Round Rock Independent School District — tax counsel to issuer in connection with $96.1 million of Unlimited Tax School Building and Refunding Bonds, Series 2016

Texas Department of Housing and Community Affairs — tax counsel to issuer in connection with $29.5 million of Multifamily Notes (Mercantile Apartments Project), Series 2016

Texas state agency — received a favorable ruling under the "taxable mortgage pool" regulations that allowed the client to sell mortgages purchased with proceeds of tax-exempt bonds without requirement a simultaneous redemption of the bonds, providing the client with the desired flexibility to administer their program

Dallas County, Texas — tax counsel to issuer in connection with $167.9 million of Combination Tax & Parking Revenue Certificates of Obligation, Series 2016

Texas community college system — provided an opinion regarding a private business use analysis of multiple facilities with various types of private business use

The Woodlands Road Utility District No. 1 — tax counsel to issuer in connection with $13 million of Unlimited Tax Road Refunding Bonds, Series 2016

Houston Housing Finance Corporation — tax counsel to issuer in connection with $17.5 million of Multifamily Housing Revenue Bonds (New Hope Housing at Reed), Series 2016

Bexar County Hospital District (d/b/a University Health System) — tax counsel to issuer in connection with $199.2 million of Limited Tax Refunding Bonds, Series 2016

Board of Regents of the University of Texas System — tax counsel to issuer in connection with $117.2 million of Permanent University Fund Bonds, Series 2016A

Lone Star College System — tax counsel to issuer in connection with $133.2 million of Limited Tax General Obligation Refunding Bonds, Series 2016 and $11.4 million Maintenance Tax Refunding Bonds, Series 2016

Bexar County, Texas — tax counsel to issuer in connection with $101.7 million of Flood Control Tax Refunding Bonds, Series 2016

Texas Water Development Board — tax counsel to issuer in connection with $58.5 million State of Texas Water Financial Assistance and Refunding Bonds, Subseries 2016B-1; $30.3 million State of Texas Water Financial Assistance and Refunding Bonds, Subseries 2016B-2; $28.8 million State of Texas Water Financial Assistance Refunding Bonds, Subseries 2016C-1 (Economically Distressed Areas Program); and $11.5 million State of Texas Water Financial Assistance Refunding Bonds, Series 2016D (State Participation Program)

Spring Independent School District — tax counsel to issuer in connection with $80.1 million of Unlimited Tax Refunding Bonds, Series 2016

Fort Bend Independent School District — tax counsel to issuer in connection with $70.5 million of Unlimited Tax Refunding Bonds, Series 2016

Alamo Regional Mobility Authority — tax counsel to issuer in connection with $62.1 of Senior Lien Vehicle Registration Fee Revenue Bonds, Series 2016 and $52.3 million Junior Lien Vehicle Registration Fee Revenue Bonds, Series 2016

Central Texas Regional Mobility Authority — tax counsel to issuer in connection with $358 million of Senior Lien Revenue Refunding Bonds, Series 2016 and $298.7 million of Senior Lien Revenue Bonds, Series 2015A; and $68.7 million of Senior Lien Revenue and Refunding Put Bonds, Series 2015B

Travis County, Texas — tax counsel to issuer in connection with $42 million of Certificates of Obligation, Series 2016; $25.1 million Unlimited Tax Road Bonds, Series 2016; $14 million State Highway System Bonds, Series 2016; and $8.8 million Permanent Improvements Bonds, Series 2016

City of Waco, Texas — tax counsel to issuer in connection with $82.6 million of Combination Tax and Revenue Certificates of Obligation, Series 2016 and $29.4 million General Obligation Refunding Bonds, Series 2016

Texas Department of Housing and Community Affairs, Veterans' Land Board of the State of Texas — tax counsel to issuer in connection with $31.5 million of Single Family Mortgage Revenue Bonds, 2016 Series A, $250 million State of Texas Veterans Bonds, Series 2016

Publications and Speeches

“Arbitrage and Rebate” and “501(c)(3) Bonds,” Fundamentals of Municipal Bond Law Seminar, National Association of Bond Lawyers, April 2017.

“Commentary: Management Contracts Safe Harbors Revisited – IRS Releases Updated Guidance (Again),” The Bond Buyer, January 24, 2017.

“Final Issue Price Regulations,” Texas Women in Public Finance Conference, January 20, 2017.

“Commentary: Final Issue Price Regulations Significantly Change Current Rules,” The Bond Buyer, December 14, 2016.

“Private Activity Bond Tests” and “Refundings and Reissuances,” National Association of Bond Lawyers Bond Attorneys Workshop, 2016.

“Tax Laws & Arbitrage Rules,” Texas Women in Public Finance - San Antonio Chapter, April 15, 2016.

“IRS TEB Training Session: Private Security or Payment Test,” March 9, 2016.

“IRS Takes Another Stab at Proposed Issue Price Regulations - A Step in the Right Direction, But Practical Questions Remain,” Texas Tax Lawyer, Fall 2015.

“Private Activity Bond Tests,” National Association of Bond Lawyer’s Bond Attorneys Workshop, 2015.

“Hot Tax Topics,” National Association of Bond Lawyers Tax & Securities Law Institute, 2015.

“Commentary: Simplified Settlement Procedures for Issuers of 501(c)(3) Bonds,” The Bond Buyer, January 2015.

“A Practical Guide to Successful Tax and Disclosure Post-Issuance Compliance,” Gulf Coast Government Finance Officers Association Training Session, October 2014.

“Private Activity Bond Tests,” National Association of Bond Lawyer's Bond Attorneys Workshop, 2014.

“Legislative, Treasury and Internal Revenue Service Update,” ABA Section of Taxation Meeting, Committee on Tax-Exempt Financing, May 2014.

“Private Activity Bond Tests,” National Association of Bond Lawyer's Tax & Securities Law Institute, 2014.

“Tax-Exempt Bonds: Federal Securities Law Enforcement and Tax Law Update,” Government Treasurers Organization of Texas Winter Seminar, December 2013.

Chair and Panelist, “Private Activity Bond Tests,” National Association of Bond Lawyer's Bond Attorneys Workshop, 2013.

Speaker, “Legal Issues in Generating Revenues from Bond Financed Assets,” Capital Area Texas Association of School Board Officials, January 2013.

“Private Activity Bond Tests,” National Association of Bond Lawyer's Bond Attorneys Workshop, 2012.

“If the IRS Knocks, Will Your House Be in Order?” Bond Review Board Brown Bag Lunch Series (March 2012) and the Texas School District Accounting and Auditing Conference (June 2012).

Credentials

Education

J.D.,
Harvard Law School
2002
B.A.,
Tulane University
1999
summa cum laude

Bar Admissions

Texas

Affiliations

National Association of Bond Lawyers
Vice Chair, Education and Member Services Committee, 2016 - 2017; Editorial Committee, Federal Taxation of Municipal Bonds, 2014 - 2016; Nominating Committee, 2015; Steering Committee, Bond Attorneys Workshop, 2012 - 2014, 2017
American Bar Association
Section of Taxation
State Bar of Texas
Chair, Tax-Exempt Finance Committee, 2010 - 2011; Vice-Chair, Tax-Exempt Finance Committee, 2009 - 2010
Texas Bar Foundation
Fellow
Texas Women in Public Finance
Texas Association of Local Housing Agencies
Travis County Women Lawyers
Fellow
Austin Bar Association
Tax Section

News

News

Vinson & Elkins to exit Public Finance

December 14, 2011
Bond Buyer Online, The

V&E’s Public Finance Group Moves To Bracewell

December 13, 2011
The Texas Lawbook

Events

Past Events

13th Annual Tax & Securities Law Institute

New Orleans
March 5, 2015
March 6, 2015

39th Bond Attorneys' Workshop

Chicago
September 17, 2014
September 19, 2014