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Introduction
Carla Young counsels clients on the tax requirements relating to bonds issued by state and local governments.
My focus
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, investment bankers, 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 counsel 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 the 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.
Representative experience
- Co-bond counsel (tax) to the Metropolitan Transportation Authority—North America’s largest transportation provider—and its affiliate, the Triborough Bridge and Tunnel Authority
- Co-bond counsel (tax) to the New York City Municipal Water Finance Authority, which provides water and wastewater services to almost ten million residents
- Co-bond counsel (tax) to the Dormitory Authority of the State of New York (DASNY), including bonds issued to finance nonprofit and education facilities at private institutions, and bonds issued to finance dormitory facilities at the State University of New York (SUNY)
- Bond counsel (tax) to numerous industrial development agencies and local development corporations in the State of New York for bonds issued to finance nonprofit facilities
- Co-bond counsel (tax) to the Sales Tax Securitization Corporation (City of Chicago), including the creation of the corporation and issuance of bonds backed by dedicated sales taxes
- Bond counsel (tax) to the Puerto Rico Sales Tax Financing Corporation (COFINA) for restructuring of more than $18 billion of outstanding bonds in connection with bankruptcy proceeding under the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA)
- Bond counsel (tax) to the Commonwealth of Puerto Rico for restructuring of more than $17 billion of outstanding bonds in connection with bankruptcy proceeding under the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA)
- Bond counsel (tax) to the Puerto Rico Highways and Transportation Authority for restructuring of more than $4 billion of outstanding bonds in connection with bankruptcy proceedings under the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA)
Insights
- “Financing Capital Projects on College & University Campuses & Related Post-Issuance Compliance,” National Association of College and University Attorneys, Pittsburgh, PA, June 28, 2022
- “IRS provides relief for municipal bond issuers in response to COVID-19 pandemic,” Nixon Peabody Client Alert, May 7, 2020
- “Federal tax issues relating to long-term financing of working capital expenditures,” Nixon Peabody Client Alert, April 9, 2020
- “New Proposed IRS Regulations for Transitions from the use of LIBOR to Other Interbank Offering Rates,” Nixon Peabody Client Alert, October 30, 2019
- “Bond Attorneys Workshop,” Speaker, National Association of Bond Lawyers, Chicago, IL, July 31, 2018
In the news
- The Bond Buyer
Unrated bonds latest to fund growth of Florida’s Villages senior development
Aug 29, 2024This article on an unrated $163 million land development bond for The Village Community Development District No. 15, which will fund residential infrastructure construction, mentions NP as co-bond counsel. The NP team advising on the bond deal includes Washington, DC Project Finance & Public Finance partners Bruce Serchuk and Carla Young.
- The Bond Buyer
New York City Water back in market with $450 million deal
April 15, 2024This article covers the New York City Municipal Water Finance Authority’s second bond issuance this year—$450 million of fixed-rate second resolution bonds—and mentions NP for serving as bond counsel. The NP team includes New York City Project Finance & Public Finance practice group leader Virginia Wong; Washington, DC PBFN partner Carla Young; and senior counsel Ken Lind, counsel Sebastian Torres and Abbie Olsen, and associate Greg Hom, all of the PBFN practice and New York City office.
- The Bond Buyer
New York TBTA to sell green bonds backed by state’s payroll mobility tax
Jan 16, 2024This article covers the Triborough Bridge and Tunnel Authority of New York’s plan to sell $300 million of tax-exempt green bonds, which will be used to finance transit and commuter projects in New York City. The article mentions NP for serving as bond counsel in the sale. The NP team includes New York City partners Liz Columbo and Adam Gordon, Washington, DC partner Carla Young, New York City senior counsel Ken Lind, and New York City associates Paul Dewey, Georgia Sackey, and Katharine Stack, all of the Project Finance & Public Finance practice.
- The Bond Buyer
City of Chicago, Sales Tax Securitization Corporation win Deal of the Year
Dec 5, 2023This article recaps the publication’s “Deal of the Year” being awarded to the City of Chicago and its Sales Tax Securitization Corporation (STSC) for a $1.7 billion financing to address initiatives related to affordable housing, homeless support services, environmental justice, and community development. NP served as bond counsel to STSC in connection with a social bonds component of the deal, which included issuance of $750 million of bonds. The NP team was led by New York City partner and Project Finance & Public Finance practice group leader Virginia Wong and included PBFN partner Carla Young and Corporate partner Lloyd Spencer, both of Washington, DC; counsel Abigail Olsen of New York City and Sharone Levy of Chicago; New York City associate Paul Dewey, and New York City senior paralegal Patrick McGovern, all of the PBFN practice. The article also mentions Virginia for receiving the Freda Johnson Award for the private sector, which recognizes trailblazing women working in public finance. Click here to watch Virginia’s acceptance speech.
- The Bond Buyer
$765M Triborough Bridge and Tunnel Authority deal draws focus
Jan 5, 2023This article covers client Triborough Bridge and Tunnel Authority’s $765 million Payroll Mobility Tax Senior Lien Refunding Green Bonds, which were priced Thursday in the primary market. The NP team serving as bond counsel on this deal includes New York City partners Ken Lind, Liz Columbo, and Adam Gordon; Washington, DC partner Carla Young; New York City counsel Abigail Olsen; and New York City associates Kate Stack, Paul Dewey, and Georgia Sackey, all of the Project Finance & Public Finance practice.
- El Nuevo Dia
The Highways and Transportation Authority’s adjustment plan goes into effect
Dec 7, 2022This article, which covers a debt restructuring of the Puerto Rico Highways and Transportation Authority outstanding indebtedness, mentions NP as legal advisors on the new indebtedness. The NP team includes Project Finance & Public Finance practice group leader Virginia Wong from New York, Washington, DC partners Mitch Rapaport and Carla Young, Los Angeles partner Angelica Valencia, New York associate Sebastian Torres-Rodriguez, and New York senior paralegals Carolyn Yi-Medina and Patrick McGovern, all of the Project Finance & Public Finance group.
- The Bond Buyer
Puerto Rico's restructured bonds will be exempt, and provide fresh high-yield liquidity
This article on Puerto Rico’s restructured general obligation bonds mentions NP for the firm’s determination that the bonds will be tax-exempt. The NP team is comprised of New York City partners Virginia Wong, Ken Lind, and Liz Columbo, and associate Sebastian Torres; Washington, DC partners Mitch Rapaport and Carla Young; and Los Angeles partner Angelica Valencia, all of the Project Finance & Public Finance group.March 3, 2022 - The Bond Buyer
Market sectors and segments pointed volume down in the Northeast
The article on the state of the municipal bond markets mentions NP for serving as bond counsel on the Triborough Bridge and Tunnel Authority’s $1.24 billion payroll mobility tax senior lean deal for MTA Bridges and Tunnels. The NP team included New York partners Liz Columbo, Ken Lind, Adam Gordon, Chris Reitzel, and counsel Abigail Olsen, and Washington DC partner Carla Young, all of the Project Finance and Public Finance group.Feb 25, 2022 - The Deal
Deal diary-Blackstone and KKR chalk up more insurance investments
July 15, 2021In two separate articles, the publication highlighted the firm for advising American International Group, Inc. in the pending sale of a $5.1 billion affordable housing portfolio to Blackstone Real Estate Income Trust. Washington, DC Community Development Finance partner Liz Young is noted in one of the stories for leading the NP deal team.
In addition to Liz, the NP team includes Affordable Housing & Real Estate partner Dara Histed, Project Finance & Public Finance partner Carla Young, Community Development Finance senior counsel Jeff Lesk, and Corporate partner John Partigan, all of Washington, DC; Global Finance partner Amanda Darwin, Affordable Housing & Real Estate associates Julie Stande and Ali Walendziak, and Community Development Finance associate Nury Aguasvivas, all of Boston; Affordable Housing & Real Estate associate Emily Schwebke and Project Finance & Public Finance resident attorney Jacalyn Smith, both of Chicago; Manchester Affordable Housing & Real Estate associate Talia Burghard; Long Island Affordable Housing & Real Estate paralegal Lori Esposito; and Los Angeles Corporate paralegal Mina Gonzaque-Taylor.
- Law360
New remedial actions for tax-advantaged bonds and P3s
Nixon Peabody public finance partners Travis Gibbs of San Francisco and Mitch Rappaport, Bruce Serchuk and Carla Young of Washington DC co-wrote this analysis on the new IRS procedures that can be used “to cure impermissible use of bond-financed projects.”April 20, 2018 - The Bond Buyer
Carla Young Joins Nixon Peabody
This feature story highlights the arrival of Washington, DC, Public Finance partner Carla Young.June 3, 2014
Admitted to practice
District of Columbia
Education
Georgetown University Law Center, J.D., cum laude
Rutgers University, B.A., Accounting, with high honors
Professional activities
- National Association of Bond Lawyers (NABL), Member and Speaker
Recognition
- Selected, through a peer-review survey, for inclusion in The Best Lawyers in America® 2024 in the field of Public Finance Law
- Received US Treasury performance award related to work during financial crisis, 2008 (received while with the IRS)
- Received IRS Chief Counsel performance awards, 2006–2009 (Received while with the IRS)
Insights And Happenings
View AllProfessionals in the Practice Area
View AllVirginia Wong
Partner / Practice Group Leader, Project Finance and Public Finance- New York
- Office:+1 212.940.3028
- vwong@nixonpeabody.com
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Julie K. Seymour
Partner / Strategic Impact Partner- Chicago
- Office:+1 312.977.4353
- jkseymour@nixonpeabody.com
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Scott R. Singer
Partner- New York
- Office:+1 212.940.3182Mobile:+1 917.886.5967
- ssinger@nixonpeabody.com
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