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Christie L. Martin

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[email protected]

+1.617.348.1769

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Christie Lombard Martin leads the public finance tax practice at Mintz Levin and focuses her practice on tax matters in connection with the firm’s roles as bond counsel, underwriter’s counsel, borrower’s counsel and purchaser’s counsel for a variety of municipal bond issues.  She acts as bond counsel and tax counsel for issuers and conduit borrowers in the health care, government, education, financial services, and nonprofit sectors and is experienced with both taxable and tax advantaged bonds including governmental general obligation and revenue bonds, qualified 501(c)(3) bonds, working capital bonds, exempt facility bonds and other private activity bonds.  

Christie works with issuers and conduit borrowers to develop and implement effective post-issuance compliance procedures.  She assists with private use analysis and strategies and when necessary represents issuers and conduit borrowers in resolving issues through the IRS voluntary closing agreement program.  Christie also represents issuers and conduit borrowers in connection with IRS bond examinations. Christie currently serves as the Vice Chair of the National Association of Bond Lawyers Tax Law Committee.  She is a frequent panelist at industry conferences and has served as editor-in-chief of the Federal Taxation of Municipal Bonds Deskbook.

Education

  • Harvard Law School (JD, cum laude)
  • University of Massachusetts - Amherst (MPA)
  • College of the Holy Cross (BA, cum laude)

Experience

  • Served as bond and borrower counsel to College of the Holy Cross with respect to refunding bonds issued by the Massachusetts Development Finance Agency and bank loan amendments.
  • Served as bond and borrower counsel to Partners HealthCare System, Inc. with respect to new money and refunding bonds issued by the Massachusetts Development Finance Agency and the New Hampshire Health and Education Facilities Authority and with respect to direct issues of taxable bonds
  • Served as bond and borrower counsel to Merrimack College with respect to new money bonds issued by the Massachusetts Development Finance Agency.
  • Served as bond counsel to the Commonwealth of Massachusetts in connection with new money/advance refunding bonds including “green bonds” used to finance a variety of environmentally beneficial projects.
  • Represented the Commonwealth of Massachusetts as bond counsel and disclosure counsel on this combined new money/advance refunding issue involving General Obligation Bonds, Consolidated Loan of 2016, Series F (Green Bonds) (Federally Taxable), and General Obligation Refunding Bonds, 2016 Series B. The transaction featured the Commonwealth’s third issuance of “green bonds” to finance a variety of environmentally beneficial projects, with the green bonds being sold as taxable bonds to maintain maximum flexibility with respect to private sector involvement with the financed projects.
  • Bond and agency counsel to the Massachusetts Development Finance Agency in connection with bonds and notes issued for the financing of various capital projects for institutions of higher education and hospitals.

Recognition & Awards

  • Chambers USA: Massachusetts – Banking & Finance: Public Finance (2017)

Involvement

  • Member, National Association of Bond Lawyers
  • Member, Massachusetts Bar Association
  • Member, Maine Bar Association
  • Member, American Bar Association: Section of Taxation

Recent Insights

News & Press

Viewpoints

The IRS on April 11, 2018 released Revenue Procedure 2018-26 (Rev. Proc. 2018-26), which include the expansion of remedial action options in connection with certain post-issuance leases to private parties of facilities financed with tax-exempt bonds.
The IRS on April 11, 2018 released Revenue Procedure 2018-26 (Rev. Proc. 2018-26), which expands remedial action options in connection with certain post-issuance leases to private parties of facilities financed with tax-exempt bonds.
On September 28, 2017, the Internal Revenue Service (IRS) withdrew previous proposed regulations and released new proposed regulations (the “Proposed Regulations”) relating to public approval requirements for tax exempt private activity bonds. 
As the Trump administration attempts to substantially reduce the amount of federal regulations, both the Deputy Tax Legislative Counsel of the Treasury Department and an Associate Chief Counsel at the Internal Revenue Service indicated this week that we are likely to see a virtual halt to formal tax law “guidance” for the foreseeable future.
In August, 2016, the IRS issued Revenue Procedure 2016-44, the first comprehensive revision of its management contract safe harbors since Revenue Procedure 97-13.  Rev. Proc. 2016-44 (see our description here) built upon and amplified principles laid out in private letter rulings issued over many years and in Notice 2014-67. 
After two sets of proposed regulations, Treasury and IRS have now released final regulations on the definition of “issue price” for purposes of arbitrage investment restrictions that apply to tax-advantaged bonds (the “Final Regulations”) and it appears that the third time’s the charm.
The IRS on August 22, 2016 released long-anticipated Revenue Procedure 2016-44 (Rev. Proc. 2016-44), which substantially increases flexibility in, and provides a less formulaic approach to, the ability of a tax-exempt bond issuer or 501(c)(3) conduit borrower to contract with private parties without jeopardizing the tax-exemption of bonds that financed the facilities at which the applicable services are provided.
Treasury and IRS today announced a decision to withdraw the much-criticized portion of the notice of proposed rulemaking published in the Federal Register on September 16, 2013 (the “2013 Proposed Regulations”) related to the definition of issue price for tax-advantaged obligations and to propose a revised definition of issue price in its place.

News & Press

Mintz partner and Massachusetts lawyer Julie Korostoff is one of 49 attorneys recognized as “Leaders in Their Fields” by the 2018 Chambers USA: America's Leading Lawyers for Business guide. Chambers named Korostoff a “Recognized Practitioner” in Technology.
The 2017 Chambers USA: America's Leading Lawyers for Business guide ha recognized 49 Mintz attorneys as “Leaders in Their Fields.” Practice highlights include top rankings for banking and finance.
Mintz served as co-bond counsel to the Brooklyn Arena Local Development Corporation in the refinancing of certain bonds issued for the construction of the Barclays Center in Brooklyn, NY.

Events

Panelist
Dec
7
2015

2015 Tax Exempt Bond Compliance Workshop

Treasury Institute for Higher Education

Hilton Orlando Lake Buena Vista, Orlando, FL