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About Victoria

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.     

Experience

Recent Notable Matters

Central Texas Regional Mobility Authority — tax counsel in connection with issuance of senior and subordinate lien revenue bonds for toll road projects

City of Austin, Texas — tax counsel in connection with issuance of governmental and private activity bonds for projects at City’s Austin-Bergstrom International Airport

Cypress-Fairbanks Independent School District — tax counsel in connection with issuance of new money bonds for District projects and refunding bonds to refinance debt previously issued by the District, including the refunding of taxable build America bonds

Dallas Independent School District — tax counsel in connection with District’s commercial paper program, as well as the issuance of new money bonds for District projects and refunding bonds to refinance debt previously issued by the District

City of Deer Park, Texas — tax counsel in connection with issuance of governmental bonds issued for City projects

Fort Bend Independent School District — tax counsel in connection with District’s commercial paper program, as well as the issuance of new money bonds for District projects and refunding bonds to refinance debt previously issued by the District

City of Houston, Texas, Houston Airport System — tax counsel in connection with issuance of governmental and private activity bonds for projects at George Bush Intercontinental Airport and William P. Hobby Airport

City of Mesquite, Texas — tax counsel in connection with issuance of governmental bonds issued in connection with permanent improvement districts created by the City

Midtown Redevelopment Authority — tax counsel in connection with issuance of tax-exempt draw down loan and governmental bonds

Port Freeport — tax counsel in connection with issuance of governmental and private activity bonds for projects at the Port

Old Spanish Trail/Almeda Redevelopment Authority — tax counsel in connection with issuance of new money bonds for redevelopment projects and refunding bonds to refinance debt previously issued by the Authority

Round Rock Independent School District — tax counsel in connection with issuance of new money bonds for District projects and refunding bonds to refinance debt previously issued by the District, including the advance refunding of taxable build America bonds

San Jacinto River Authority — special tax counsel in connection with the refunding of governmental and private activity bonds previously issued by the Authority

Texas Department of Housing and Community Affairs — tax counsel in connection with multiple issues of qualified mortgage bonds and multifamily housing bonds, as well as with respect to mortgage credit certificate program and low-income housing tax credits

Texas Veterans Land Board — tax counsel in connection with multiple issues of qualified veterans’ mortgage bonds

Travis County — tax counsel in connection with new money bonds for County projects and refunding bonds to refinance debt previously issued by the District

The Woodlands Township, Texas — special tax counsel in connection with the refunding of tax-exempt debt previously issued by the Township

Texas city — successfully represented city in connection with an Internal Revenue Service audit relating to a remedial action previously undertaken by the city

Texas community college system — provided an opinion regarding a private business use analysis of multiple facilities with various types of private business use

Texas river authority — received a favorable private letter ruling regarding the allocation of governmental and exempt facility bonds to expenditures for costs of projects for various issuer facilities

Texas state agency — successfully represented agency in connection with an Internal Revenue Service audit relating to pool financing utilized to make conduit loans

Texas state agency — received a favorable ruling under the "taxable mortgage pool" regulations that allowed the client to sell mortgages purchased with proceeds of tax-exempt bonds without requirement a simultaneous redemption of the bonds, providing the client with the desired flexibility to administer their program

Publications and Speeches

"Tax Diligence and Documentation," The Workshop, National Association of Bond Lawyers, September 11-13, 2019.

"Tax-Exempt Bonds Essentials," UT Law's 2019 Higher Education Taxation Essentials, June 2, 2019.

“Avoiding Private Activity Panel,” The Essentials, National Association of Bond Lawyers, April 24-26, 2019.

"Proposed Bill Would Reinstate Tax-Exempt Advance Refundings," American Health Lawyers Association, February 19, 2019

"Final Public Approval Regulations Step into the 21st Century," The Bond Buyer, January 8, 2019.

“It’s Official!  Public Approval Regulations Now Reflect the 21st Century,” TALHFA Talk Winter 2018/2019

“Post-Issuance Compliance,” Texas Rural Education Association Summer Meeting, June 2018.

"IRS Provides Issuers of Tax-Advantaged Debt With New ‘DIY’ Tools to Fix Nonqualified Use," Bloomberg Tax, May 28, 2018.

"Mixed Messages on PABs: Fit for the Chopping Block or Cornerstone of Infrastructure Finance?," Bloomberg Tax, March 14, 2018.

"Expert Analysis: The Public Finance Industry Dodged a Tax Reform Bullet,” Law360, January 12, 2018.

"As SLGS Window Closes, Tax Reform Continues to Threaten Public Finance," The Bond Buyer, December 12, 2017.

“Covering the Bases for Potential Tax Reform,” The Bond Buyer, November 21, 2017.

“Internal Revenue Service to Begin New Procedure for Initiating Tax-exempt Bond Audits,” American City & County, April 11, 2017.

“Arbitrage and Rebate” and “501(c)(3) Bonds,” Fundamentals of Municipal Bond Law Seminar, National Association of Bond Lawyers, April 2017.

"New Issue Price Regulations : The Good , the Bad and the Ugly," The Bond Buyer, February 8, 2017.

“Commentary: Management Contracts Safe Harbors Revisited – IRS Releases Updated Guidance (Again),” The Bond Buyer, January 24, 2017.

“Final Issue Price Regulations,” Texas Women in Public Finance Conference, January 20, 2017.

Credentials

Education

Harvard Law School,
J.D.
2002
Tulane University,
B.A.
1999
summa cum laude

Bar Admissions

Texas

Affiliations

National Association of Bond Lawyers
Board of Directors, 2019; Chair, Education and Member Services Committee, 2017-2019; Vice Chair, Education and Member Services Committee, 2016 - 2017; Editorial Committee, Federal Taxation of Municipal Bonds, 2014 - 2016; Nominating Committee, 2015; Steer
State Bar of Texas
Tax Section; Chair, Tax-Exempt Finance Committee, 2010 - 2011; Vice-Chair, Tax-Exempt Finance Committee, 2009 - 2010
Texas Bar Foundation
Fellow
Women in Public Finance
Texas Association of Local Housing Agencies
Travis County Women Lawyers
Fellow
Austin Bar Association
Tax Section

News

Insights

Insights

Spotlight on Public Finance, Spring 2019

Featured Articles: Hackers Continue to Target Public Sector Entities; Credit Ratings and Infrastructure at Risk,
Negotiating Your “Standard” Construction Contract

Spotlight on Public Finance, Spring 2018

Featured Article: Only You Can Prevent Cyber-attacks: How to Spot the Fires and Put Them Out

Noteworthy

Noteworthy

NABL 2019 President’s Service Award

Events

Past Events

13th Annual Tax & Securities Law Institute

New Orleans
March 5, 2015
March 6, 2015

39th Bond Attorneys' Workshop

Chicago
September 17, 2014
September 19, 2014