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A factor that distinguishes Bracewell is the depth of our tax experience both in the public finance area and in the general federal income tax area, with a number of our attorneys devoting all or significant parts of their practices to tax-exempt finance. Each of these attorneys has experience in assisting public finance clients in complying with arbitrage regulations and other tax-related requirements. Likewise, our group of tax attorneys has experience in securing private letter rulings or other rulings (including, but not limited to, extensions of time and other procedural matters) from the Internal Revenue Service (IRS) on behalf of our public finance clients, including rulings on, among other things, the use of hospital, airport, and seaport facilities, the classification of public entities, the application of certain arbitrage rules, and the definition of related persons.

Our public finance tax attorneys also have experience in the general federal tax area. Because the rules applicable to tax-exempt finance are merely part of the larger, interrelated body of federal tax law, we believe that general knowledge of other areas of tax law better equips a tax attorney practicing in the area of public finance.

Both our public finance and tax attorneys assist clients with post-closing matters, IRS inquiries, audits and examinations. Our tax attorneys regularly advise on post-issuance private business use, arbitrage, record retention, remedial actions and similar issues for both tax-exempt bonds and tax credit bonds. Because of the depth of our resources, we are able to formulate compliance documents to assist clients to match their specific needs, as necessary. Additionally, we regularly advise clients regarding the private use tests and remedial actions.

Our tax attorneys also work closely with our clients in responding to IRS communications and audits. We assist governmental clients in responding to questionnaires on advance refunding bonds and correspondence exams on multifamily housing bonds. When called upon by our clients, our attorneys have led the industry on finding paths to challenge IRS demands for excessive rebate. Further, our tax attorneys have successfully obtained favorable private letter rulings on behalf of our clients.