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Whether serving as bond counsel, underwriter’s counsel or as special tax counsel to our clients, Bracewell helps clients identify relevant tax issues associated with structuring and designing tax-advantaged financing options, including compliance with arbitrage regulations, private business use rules and other tax law requirements imposed on tax-advantaged debt. Likewise, we have experience assisting clients in post-issuance compliance matters and Internal Revenue Service (IRS) examinations, securing advance rulings from the IRS and seeking regulatory and legislative rule changes. Our attorneys regularly advise large charitable organizations regarding applicable tax rules and represent charitable organizations in all aspects of tax compliance, from initial organization and recognition under Section 501(c)(3) of the United States Internal Revenue Code to ongoing compliance and transaction structuring to IRS examinations.

Experience

Recent Notable Matters

Governmental entity — preparing a private business use analysis with respect to several issues of bonds that had financed multiple facilities with a private business use component

San Jacinto River Authority — allocation of proceeds of governmental and exempt facility bonds to expenditures for costs of projects for various issuer facilities

Utility District Advisory Corporation — comments to proposed Treasury Regulations that would redefine the term “political subdivision” for purposes of the federal tax-exempt bond rules on behalf of a trade association

Various financial advisors — eliciting support from members of the Texas congressional delegation to secure a change in Treasury Regulations and ensure that the Texas Permanent School Fund would continue to be available to guarantee bonds issued by school districts throughout the state

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