Michael Cullers focuses his practice on matters involving tax-exempt bonds and state and local taxation. Michael has extensive experience in the tax aspects of state and local bond issues, including governmental use bonds, qualified 501(c)(3) bonds and other tax-exempt private activity bonds, such as airport financings, as well as tax-advantaged bonds, such as Build America Bonds and qualified school construction bonds. This experience includes private business use and private payment analyses; arbitrage issues in new money, refunding and multipurpose bond issues; multipurpose issue allocations for advance refundings; compliance with the remedial action regulations; and issues involved with financial derivatives to be integrated with tax-exempt obligations. He has represented clients in audits of tax-exempt obligations and negotiations of closing agreements with the IRS under the voluntary closing agreement program. He has also advised on the state tax aspects of state and local bonds and investment funds that hold such obligations.
Michael writes for the Public Finance Tax blog, which is the first blog devoted exclusively to the tax issues that arise in connection with tax-advantaged state and local debt, and he has had articles on tax-advantaged bonds published by The Bond Buyer, The National Law Review, Bloomberg’s Daily Tax Report and Law360. Michael has spoken on tax-advantaged bonds at many seminars, and has spoken on other federal, state and local tax issues at the Cleveland Metropolitan Bar Association’s Business Law Practice and Procedure Clinic and the Cleveland Tax Institute. He has written extensively on Ohio state and local tax matters, including several Ohio Tax Practice Insights published by LexisNexis and an article published in the BNA Tax Management Weekly State Tax Report.
Michael is a member of the American, Ohio State and Cleveland Metropolitan Bar Associations and the National Association of Bond Lawyers.
More Legal and Business Bylines From Michael A. Cullers
- How Poker Reminded Me that the Rev. Proc. 97-13 Safe Harbors for Management Contracts Live On - (Posted On Wednesday, March 08, 2017)
- IRS Releases Interesting Private Letter Ruling on Build America Bonds - (Posted On Wednesday, January 18, 2017)
- An Open Letter to the IRS on Revenue Procedure 2016-44 - (Posted On Wednesday, November 16, 2016)
- Just in Case You Didn’t Notice – Rev. Proc. 2016-44 Treats as Compensation under a Management Contract the Reimbursement of Amounts Paid by the Manager to its Employees - (Posted On Tuesday, September 27, 2016)
- Treasury Department Releases 2016-17 Priority Guidance Plan for Tax-Exempt Bonds – And It’s Already About One-Third Complete! - (Posted On Wednesday, August 31, 2016)
- A Summary of the Final Regulations on Non-Issue Price Arbitrage Restrictions - (Posted On Friday, July 22, 2016)
- Recent IRS Private Letter Ruling Provides Helpful Guidance on Management Contracts - (Posted On Wednesday, July 06, 2016)
- Tax-Exempt Bonds: Is It Possible for a Municipal Corporation Not to be a Political Subdivision? - (Posted On Wednesday, May 18, 2016)
- Build America Bonds, Crossover Refunding – Does It Really Have to Come to This? - (Posted On Wednesday, April 06, 2016)
- The Allen Iverson Trilogy – A Postscript - (Posted On Wednesday, February 17, 2016)