Charlie Almond has more than 40 years of experience practicing law and specializing in federal income tax matters – in particular, federal income tax matters relating to state and local government bonds and public finance.
Mainstays of Charlie’s practice have included: (i) structuring and opining on a wide variety of governmental and private-activity-bond financings in a traditional bond counsel/underwriter counsel capacity; (ii) representing issuers and conduit borrowers in Internal Revenue Service audits of their bonds; (iii) representing issuers and conduit borrowers seeking resolution of unresolved legal issues by obtaining private letter rulings from the Internal Revenue Service; and (iv) advising and representing a variety of clients seeking/opposing, advocating, and obtaining federal legislative and regulatory rule changes relating to State and local bonds.
Charlie has dealt extensively with Congressional, Treasury and Internal Revenue Service personnel on both technical and tax-policy issue relating to public finance. Having practiced in the public finance arena for as long as he has, Charlie is well acquainted and friendly with many public finance lawyers and bankers on both coasts and in most states in between.
Recent Notable Matters
Mission Economic Development Corporation — bond counsel to issuer in connection with $336.430 million Senior Lien Revenue Bonds (Natgasoline Project) Series 2018; $50 million Mission Economic Development Corporation Senior Lien Revenue Bonds (Natgasoline Project), Series 2016A; and $202.885 million Mission Economic Development Corporation Senior Lien Revenue Bonds (Natgasoline Project), Series 2016B
Political subdivisions government financing clients — Traditional bond and underwriter counsel for virtually every type of political subdivision in the State of Texas issuing bonds including the state, state agencies, state universities, water authorities, cities and counties; river, water, sports, transit authorities; municipal utility districts and other special districts. Recent clients include Dallas-Fort Worth International Airport and Dallas Area Rapid Transit.
National and regional underwriting firms — underwriter’s counsel for financings ranging from straightforward (e.g. new money bonds for traditional government facilities secured by a pledge or ad valorem taxes) to complex (e.g. stadium bonds and “prepaid gas” financings)
Private Activity Bond counsel — bond counsel and/or underwriter counsel on most types of tax-exempt private activity bond financings for projects including airports, seaports, solid waste facilities, sewage facilities, water-furnishing facilities, local district heating/cooling facilities, housing, 501(c)(3) organizations, student loans, small-issue manufacturing facilities, and facilities constructed after natural disasters
Private Activity Bond counsel — $253 million bond issued by Mission Economic Development Corporation to finance wastewater treatment facilities qualifying as sewage facilities at a methanol production facility owned by Natgasoline
Government issuers/conduit borrowers in IRS bond audits — bond issues financing a city-owned convention center hotel, a county-owned detention facility, and privately-owned solid waste disposal facilities to dispose coal ash and refinery waste, as well as an audit of a school district’s advance refunding bonds
IRS Private Letter Ruling client — obtained a ruling for Dallas-Fort Worth Airport holding that a major airport could treat its inter-terminal-building transportation facilities (a bus system on the “non-secure” side of the terminal buildings and a train system on the “secure side” of the buildings) as discrete facilities, separate from the terminal buildings, that qualify for governmental (“non-AMT”) financing
IRS Private Letter Ruling client — obtained a ruling for the Texas Department of Housing and Community Affairs allowing an issuer of tax-exempt single-family-mortgage-revenue bonds to sell bond-financed mortgages without a simultaneous redemption of bonds and without causing a violation of “taxable mortgage pool” rules
IRS Private Letter Ruling client — obtained a ruling for the San Jacinto River Authority that determines how facilities for the furnishing of water can be divided between facilities qualifying for tax-exempt (non-AMT) governmental financing and tax-exempt (AMT) private-activity-bond financing
IRS Private Letter Ruling client — obtained a ruling under new allocation/accounting regulations allowing a city-owned utility to tax-exempt finance its ownership interest in an electric generating facility jointly owned by Tenaska, a private utility, under a co-ownership arrangement that creates a partnership for federal income tax purposes
Utility District Advisory Corporation — represented a group, acting on behalf of special districts in Texas, that opposed the regulatory re-definition of “political subdivision” proposed by IRS and Treasury, and authored a comprehensive set off comments on those proposed regulations
Financial advisors on behalf of a school district — successful effort to secure an increase in a federal limitation on the amount of bonds that can be guaranteed by the Permanent School Fund of the State of Texas without running afoul of a federal exception to the arbitrage rules granted to the Fund
Publications and Speeches
Regular panelist at the National Association of Bond Lawyers’ annual Bond Attorneys’ Workshop and at meetings of the Committee on Tax-Exempt Finance of the Section of Taxation of the American Bar Association.
“Covering the Bases for Potential Tax Reform,” The Bond Buyer, November 21, 2017.
“Make America Great Again Bonds?” The Bond Buyer, January 17, 2017.