He participates in the structuring, analyzing and documenting tax-exempt financing transactions in connection with the firm’s role as bond counsel and borrower’s counsel. He is also experienced in and provides representation for federal tax controversy matters, including the negotiating of closing agreements, VCAP applications and requests for private letter rulings. Irving works closely with other members of our Bond Work Team.
Irving has over 30 years of experience as a tax attorney. His experience encompasses diverse financing transactions such as state and local government bond issues for governmentally owned facilities, including: roads, airport facilities, colleges and other schools, hospitals, sports facilities, energy conservation facilities, landfills and fire protection facilities and equipment; conduit financing of facilities owned and operated by 501(c)(3) organizations, including continuing and skilled care facilities, charter schools, universities and colleges, and health care facilities; smaller local government bond issues for infrastructure improvements; and privately owned and operated exempt facilities and industrial development facilities, including residential housing, single family mortgage revenue bonds, docks and wharves, water and sewer facilities, and solid waste disposal facilities, among others.
Irving has frequently participated in the preparation of comments by the ABA Tax Section and the National Association of Bond Lawyers to the Internal Revenue Service. He is a panelist at the Bond Attorneys Workshop panel “Tax Issues for 501(c)(3) Financing” and was recently a tax panelist at the annual meeting and seminar of the Pennsylvania Association of Bond Lawyers.
Issuers, include: states, municipalities, school districts, state and regional authorities (utilities, recreation, water, sewerage, housing, economic development, heath care, education, etc.), on behalf of issuer and special services and taxing districts.
Obligations, include: governmental bonds – general obligation bonds, revenue bonds, structuring 3P bonds, Build America Bonds, Recovery Zone Economic Development Bonds, Recovery Zone Facility Bonds; 501(c)(3) bonds; private activity bonds (conduit financing) – exempt facilities and small issue manufacturing facilities, low and moderate income housing, mortgage subsidy bonds, TRANs, lease financing and certificates of participation and current and advance refundings.
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