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REPRESENTATIVE EXPERIENCE

Virginia Leggett Stevenson

Assisted REIT with asset acquisition involving REIT tax qualifiication issues relating to large LED sign
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
Analyzed property identification issues with respect to 1031 exchange
Provided advice to various mutual funds regarding LIBOR cessation and transition to SOFR
Provided advice on avoiding "taxable mortgage pool" status
Represented sovereign wealth fund in the creation of grantor trust investment structure and purchase of mortgage loans
Represented mortgage REIT in creation of grantor trust investment structure and purchase of small-balance commercial mortgage loans
Served as tax counsel to mortgage REIT on various matters including merger-related tax matters and opinion
Served as general tax counsel to mortgage REIT
Provided tax assistance with various reorganizations and tax-free mergers of mutual funds
Provided advice to 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 REMIC trustee regarding tax consequences of settling representation and warranty litigation against loan seller and providing for various servicing improvements
Advised REIT on tax implications of TBA investments
Advised 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
Represent underwriters of Ginnie Mae, Freddie Mac and Fannie Mae REMIC and grantor trust certificates
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 REIT with tax issues involving solar energy, equipment, and net metering issues
Assisted REIT with REIT tax compliance and inbound investment issues
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