Walter R. Calvert
Walter Calvert focuses on public finance, project finance, federal, state and local taxation, and exempt organizations.
As tax counsel in municipal financing transactions, Mr. Calvert advises issuers and conduit borrowers in connection with new issues and restructurings of existing issues. His experience includes financings for governmental issuers, 501(c)(3) organizations, manufacturing and other exempt facilities, and housing bonds.
He also has extensive experience in the use of derivative products in connection with public finance, including interest rate swaps and synthetic refundings.
In credit-market financings, Mr. Calvert's experience includes transactions involving:
- commercial paper
- variable rate demand bonds
- tax increment financing
- auction rate bonds
- development districts
- bank qualified issues
- bond, tax and revenue
- anticipation notes
- current and advance refundings
In audits of municipal-bond issues by the Internal Revenue Service, Mr. Calvert's work includes resolving compliance issues prior to an audit, as well as representing clients at all other stages of audits.
He assists clients with implementing post-issuance compliance procedures in accordance with the recent IRS emphasis that beneficiaries of tax-exempt financing have appropriate personnel and protocols in place to ensure compliance with federal income tax laws.
For project financings, he serves as tax and finance counsel, particularly for projects using tax credits, either alone or in combination with tax-exempt financing. Mr. Calvert has extensive experience with financings that involve combinations of state and federal tax credits.
In regard to state and local taxation, Mr. Calvert represents individuals and businesses in transactional tax planning to assure compliance with applicable tax laws in connection with the minimization of tax burdens.
He represents taxpayers before state and local taxing authorities in audits and other tax controversies as well as in pursuing refund claims. He has provided single-state and multi-state planning for various taxes including income, franchise, sales and use, admission and amusement, recordation and transfer, and personal and real property taxes.
In the tax-exempt area, Mr. Calvert organizes and incorporates nonprofit groups in Maryland. He prepares and submits applications for tax-exempt status for various categories of exempt organizations and has assisted in corporate reorganizations of exempt organizations. He is particularly skilled in analyzing unrelated-business-income and private-inurement issues.
Significant Matters
Mr. Calvert recently worked on the creation of a special taxing district for Montgomery County; the sale of Deaton Hospital to the University of Maryland Medical System; represented municipalities in connection with SEC and IRS investigations; and the incorporation, determination of exempt status and analysis of tax issues for subsidiaries of Liberty Medical Center. He also worked with individuals to submit offers in compromise of their federal income tax liabilities.