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SLGS Window Reopening; Sequestration Extended Through FY 2029

The Bipartisan Budget Act of 2019 (the “Act”), which suspends the federal debt limit through July 31, 2021, was signed into law on August 2, 2019.  As a result, the U.S. Department of the Treasury has announced that it will resume the sale of United States Treasury Obligations – State and Local Government Series (i.e., SLGS), effective Monday, August 5, 2019, at noon Eastern Time.  The SLGS window has been closed since March 1, 2019, and issuers and conduit borrowers who otherwise may have purchased SLGS as part of their investment strategies have been forced to pursue alternate options, such as bidding securities on the open market.

The Act also extends the sequestration reductions applicable to direct pay tax credit bonds, which had been set to expire at the end of 2027, through fiscal year 2029.  Click here for a summary of the fiscal year 2020 sequestration rate

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R. Todd Greenwalt, Tax Attorney, Bracewell Law Firm
Partner

Todd's practice focuses on governmental entities and tax-exempt organizations, advising clients with regard to tax-exempt financings and other business transactions, and resolving tax-exempt status issues.

His clients include all types of state and local governmental entities, hospitals, other health care organizations, colleges and universities, charter schools, museums, arts organizations, community and economic development organizations, private foundations, advocacy groups, and other charities. Todd serves as bond counsel and advises health...

713-221-1138
Victoria N. Ozimek, Bracewell, Tax Credit Obligations Lawyer, bond Issuance Attorney
Partner

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. In addition to traditional state and local government financings, Victoria has worked on transactions for the financing of multifamily and single family housing, universities and colleges, charter schools, airports and seaports, and water facilities. 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 experience needed. 

In addition to advising clients regarding the structuring of transactions, 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. Victoria is the current chair of the Education and Member Services Committee for the National Association of Bond Lawyers and is a frequent speaker on tax matters with respect to tax-advantaged debt.     

512-542-2103
Brian P. Teaff, Business Transaction Attorney, Bracewell Law Firm
Partner

Brian Teaff has a multifaceted tax practice, advising clients in connection with tax-exempt financings and other business transactions in the public finance area, as well as counseling public charities and private foundations on a wide range of tax planning and compliance matters. In addition, Brian advises a variety of types of clients with respect to the "opportunity zone" provisions enacted under the Tax Cuts and Jobs Act of 2017. 

In his public finance practice, Brian serves as tax counsel on governmental and conduit financings where he...

713-221-1367