Nixon Peabody LLP
Carla Young is a partner in the Project Finance and Public Finance group, where her practice focuses on the tax requirements relating to bonds issued by state and local governments.
What do you focus on?
My work focuses on the tax aspects of municipal bond financings, including tax-exempt, taxable, and tax-advantaged debt obligations issued by or on behalf of state and local governments. I represent issuers, borrowers, underwriters, and lenders in a wide variety of bond issues that finance transportation and infrastructure projects, water and wastewater systems, governmental facilities, nonprofit facilities, K-12 and higher education facilities, charter schools, and public infrastructure located in community development districts, among others.
I also represent issuers with the tax issues relating to restructurings of defaulted bond issues, including restructurings connected with bankruptcy proceedings. I frequently represent issuers and borrowers before the Internal Revenue Service (IRS) in connection with requests for private letter rulings, bond examinations, and closing agreements.
Previously, I was an attorney and assistant branch chief in the Tax-Exempt Bond Branch of the Office of Chief Counsel (Financial Institutions and Products) at the IRS, where I was responsible for drafting published guidance and rulings, including guidance relating to Build America Bonds and other direct-pay obligations, as well as disaster area bonds. I also served as the Chief Counsel representative to the Tax-Exempt Bond Focus Group, which provides assistance to IRS agents in connection with examinations of tax-exempt bond issues. My experience in the government provides a unique perspective when counseling clients on issues relating to IRS bond audits and ongoing compliance with the tax rules, including the permitted uses of bond-financed facilities and actions that can be taken to remediate post-issuance noncompliance.
Since the beginning of 2020, I have been assisting municipal issuers with the impact of COVID-19, including restructurings to address related liquidity concerns, and served as co-bond counsel (tax) on the second Municipal Liquidity Facility transaction.