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REPRESENTATIVE EXPERIENCE

Virginia Leggett Stevenson

Represent underwriters of Ginnie Mae, Freddie Mac, and Fannie Mae REMIC and grantor trust certificates.
Obtained private letter rulings to financial institutions regarding the creation of floating-rate and inverse floating-rate grantor trust certificates in the Ginnie Mae multiclass certificates program.
Obtained private letter rulings for REITs for 9100 relief.
Provided REMIC tax advice for new issuances of securities backed by pools of reperforming and non-performing mortgages; provide REMIC tax advice regarding trust amendments and terminations.
Assisted a REIT with asset acquisition involving REIT tax qualification issues relating to large LED sign.
Analyzed property identification issues with respect to 1031 exchanges.
Provided advice to various mutual funds regarding LIBOR cessation and transition to SOFR.
Provided advice on avoiding "taxable mortgage pool" status.
Represented a sovereign wealth fund in the creation of grantor trust investment structure and purchase of mortgage loans.
Represented a mortgage REIT in creation of grantor trust investment structure and purchase of small-balance commercial mortgage loans.
Served as tax counsel to a mortgage REIT on various matters, including merger-related tax matters and opinion.
Served as general tax counsel to a mortgage REIT.
Provided tax assistance with various reorganizations and tax-free mergers of mutual funds.
Provided advice to a REMIC trustee regarding tax consequences of settling representation and warranty litigation against loan seller.
Provided advice regarding tax treatment of Regulated Investment Companies (RICs) and tax-related disclosure items.
Provided advice regarding tax disclosures related to self-directed IRAs that invest in RICs.
Served as tax counsel on numerous securitizations and repo transactions backed by nonperforming and reperforming residential mortgages.
Represented entities of a global fixed-income investment firm as buyer's counsel on numerous residential and commercial mortgage purchases; provide additional structuring and tax advice for new entities and business relationships.
Provided advice to a REMIC trustee regarding tax consequences of settling representation and warranty litigation against loan seller and providing for various servicing improvements.
Advised a REIT on tax implications of TBA investments.
Advised an indenture trustee with respect to various items relating to defaults.
Provided tax advice regarding the income tax treatment of employment severance payment.
Represented investment trusts in tax litigation with IRS and state tax authorities.
Served as trustee's counsel on new CMBS issuances, modifications, and terminations.
Provided tax advice in REMIC securities litigation.
Provided tax advice with regard to Code section 1033 exchange.
Served as general tax counsel to various non-mortgage REITs.
Represented investment trusts in connection with tax and insolvency matters.
Assisted a REIT with tax issues involving solar energy, equipment, and net metering issues.
Assisted a REIT with REIT tax compliance and inbound investment issues.
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