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Partner
Tax & ERISA Practice
Richmond
(804) 788-7394 Phone
(804) 788-8218 Fax
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| Practices |
Asset Securitization
CDOs and Synthetic
Structures
Derivatives
Structured Financing
Taxation: Federal,
State, Local &
Cross-Border
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Practice focuses on the federal income tax aspects of asset securitization and other capital markets transactions. Experience in the representation of collateralized debt obligations, other securitized debt offerings, specialty finance companies, derivative transactions, REMICs, and other financial products and transactions.
Relevant Experience 
- Representation of issuers, underwriters, trustees, servicers and credit enhancement providers concerning tax issues in private and public mortgage-backed and asset-backed security and debt offerings, including the representation of United States government agencies in mortgage loan securitization transactions.
- Tax structuring, evaluation and representation of various collateralized debt obligation transactions, synthetic securitization transactions, net interest margin (NIM) transactions, grantor trust and other resecuritization transactions.
- Representation of various financial institutions, including speciality finance companies, in the evaluation and tax structuring of financial products.
- Counsel clients generally on various aspects of international and United States federal, state and local income and withholding taxation.
- Representation regarding the federal income tax aspects of derivative transactions.
- Representation of REIT clients on securitized debt transactions.
Membership
- Member, Virginia State Bar
- Member, American Bar Association, Section of Taxation
Education - J.D., University of Virginia School of Law, Articles Editor, Virginia Law Review, 1998
- B.A., Washington and Lee University, magna cum laude, Philosophy, 1990
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Cecelia Horner
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