Experience Lona J. Valentine

Experience

Bond Counsel for $1.16 Billion Health Care Financing

Client: Bon Secours Mercy Health, Inc.

We served as bond counsel for Bon Secours Mercy Health, Inc., one of the nation’s 20 largest health care systems, with respect to the issuance of several series of bonds totaling $1.16 billion in aggregate principal amount. As bond counsel, we assisted with each step of the financing process, which involved the public offering of municipal tax-exempt and corporate taxable bonds involving issuers in three states. The bonds were issued in April of 2020 and enabled the financing or refinancing of health care facilities in Ohio, South Carolina, and Virginia while also contributing to the re-opening of the capital markets for health care borrowers during the COVID-19 pandemic. These combined bond deals were selected by The Bond Buyer as its 2020 Deal of the Year in the Health Care Financing Category.

IRS Letter Ruling gives school district extra time to spend bond proceeds

We obtained an IRS Private Letter Ruling to allow a public school district an extension to spend qualified school construction bond proceeds. The school would have had to spend the tax advantaged bond proceeds within three years, but the Letter Ruling allowed the district additional time to spend the bond proceeds due to unforeseen circumstances outside of the school district’s control.

$30.4 million bond used to renovate building at state university

We acted as bond counsel for a public university for the first issue of Green Bonds by a public university in the nation. The proceeds were used to fund a portion of the renovation of a building.

$91.4 million two series of bonds used to renovate public university’s football stadium

We acted as bond counsel for a public university for two issues, the proceeds of which were used to renovate the university’s football stadium. We worked with the University Architect’s office, internal tax counsellors, Athletic Department and Foundation to determine which parts of the project could be financed on a tax-exempt basis and which had to be financed on a taxable basis.

Borrower’s Counsel to private university for refunding issues

We acted as Borrower’s counsel to a private university for three refunding issues of the State of Ohio, two of which were privately placed and one of which was sold publicly. We assisted the university with matters concerning existing swap agreements, financial covenants, continuing disclosure issues and real estate matters.

Falling interest rates lead to Arbitrage Rebate recovery overpayment for city

We were able to request and obtain from the IRS recovery of an arbitrage rebate overpayment for a city. Due to interest rates falling, we were able to request and recover approximately $100,000 of a rebate overpayment from the IRS.

Over 150 Arbitrage Rebate Calculations Annually

We perform over 150 arbitrage rebate calculations annually for virtually all types of tax-advantaged bonds.

Special Tax Counsel for Tax Advantaged Bonds

We have vast experience as special counsel in IRS audits of tax advantaged bonds.

Lona J. Valentine

Experience

Bond Counsel for $1.16 Billion Health Care Financing

IRS Letter Ruling gives school district extra time to spend bond proceeds

$30.4 million bond used to renovate building at state university

$91.4 million two series of bonds used to renovate public university’s football stadium

Borrower’s Counsel to private university for refunding issues

Falling interest rates lead to Arbitrage Rebate recovery overpayment for city

Over 150 Arbitrage Rebate Calculations Annually

Special Tax Counsel for Tax Advantaged Bonds

Arbitrage Rebate Counsel for virtually every type of tax-exempt bond financing

Served as a thought leader for shaping the firm's IRS Circular 230 strategy

Special counsel to 501(c)(3) entities in completing Schedule K of the IRS Form 990

Special tax counsel to issuers and conduit borrowers in IRS bond audits

Special tax counsel to issuers and conduit borrowers IRS Voluntary Closing Agreement Program (VCAP) Requests

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Lona J. Valentine

Experience

Bond Counsel for $1.16 Billion Health Care Financing

IRS Letter Ruling gives school district extra time to spend bond proceeds

$30.4 million bond used to renovate building at state university

$91.4 million two series of bonds used to renovate public university’s football stadium

Borrower’s Counsel to private university for refunding issues

Falling interest rates lead to Arbitrage Rebate recovery overpayment for city

Over 150 Arbitrage Rebate Calculations Annually

Special Tax Counsel for Tax Advantaged Bonds

Arbitrage Rebate Counsel for virtually every type of tax-exempt bond financing

Served as a thought leader for shaping the firm's IRS Circular 230 strategy

Special counsel to 501(c)(3) entities in completing Schedule K of the IRS Form 990

Special tax counsel to issuers and conduit borrowers in IRS bond audits

Special tax counsel to issuers and conduit borrowers IRS Voluntary Closing Agreement Program (VCAP) Requests

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