| Biography | Professional Experience Linda L. D'Onofrio focuses her practice on tax law relating to public finance, and taxable and tax-exempt financial instruments, including derivative products. Ms. D'Onofrio has experience in the tax analysis and structuring of all types of municipal bond transactions (general obligation, single- and multi-family housing, 501(c)(3) organizations, private exempt activities, current and advance refundings), all forms of mortgage and asset-backed securities transactions (grantor trusts, CMOs, REITs, REMICs, Strips), bank conversions, and other financial instruments (hybrid debt, preferred stock, stripped obligations) for scores of both issuer and investment banking clients. Ms. D'Onofrio's experience includes new-product development in the municipal and structured finance areas, and she has had primary involvement in the expansion of creative financing techniques for all municipal and asset-backed securities, including the seeking of both public and private rulings from the federal government on, among other issues, the tax aspects of multi-class securities offerings, variable interest rate offerings, owner-trust/partnership structures involving stripped securities for both governmental and private entities, and the "150 Million Limitation" applicable to 501(c)(3) tax-exempt financings. Ms. D'Onofrio participated in drafting various legislative proposals that ultimately led to the passage of the REMIC provisions of the 1986 Tax Reform Act. Ms. D'Onofrio also has extensive experience in tax controversy matters involving municipal bonds. Representative Matters · Ms. D'Onofrio provided the primary tax analysis for the following matters:
- The first municipal "swaption" issued in Texas
- One of the first stripped municipal bond offerings
- The first private stripped Treasury obligations program ("TIGRs")
- The first non-governmental-agency CMO
- The first FNMA Strips program
- One of the first REMIC offerings
- Several significant municipal audits resulting in "no change" · Additionally, Ms. D'Onofrio provided the primary tax analysis as bond counsel on scores of transactions for New York State, its various agencies (including the Dormitory Authority of the State of New York), the City of New York, its various agencies (including the New York City Industrial Development Agency), and numerous other states and agencies nationally. News, Publications & Presentations · Author, "IRS Adds Questions to Form 8038-G Regarding Post-Issuance Compliance for Tax-Exempt Bonds," Day Pitney Alert, November 22, 2011 · Speaker, "Tax-Exempt Financing Opportunities," Janney Montgomery Securities Seminar, October 19, 2011 · Speaker, Bond Attorneys' Workshop, National Association of Bond Lawyers, October 12-14, 2011 · Author, "IRS Confirms Importance of Written Post-Issuance Compliance Procedures," Day Pitney Alert, September 14, 2011 · Featured, "Day Pitney's Linda D'Onofrio to be Honored for Pro Bono Municipal Finance Work," Day Pitney Press Release, April 28, 2011 · Co-author, "Expiring Tax Provisions Dramatically Change Municipal Finance Landscape," Day Pitney Alert, January 6, 2011 · Co-author, "ABA Section of Taxation Comments on Bond-Financed Grants," American Bar Association Section of Taxation, January 5, 2011 · Co-author, "Expiration of Certain Municipal Bond Tax Provisions," Day Pitney Alert, December 1, 2010 · Panelist, "Bond Financing of Grants," ABA Tax Section Fall Meeting, September 24, 2010 · Co-author, "Municipal Advisors Must Register With The SEC By October 1," Day Pitney Alert, September 2, 2010 · "Arbitrage-Overview," Bond Attorneys' Workshop, National Association of Bond Lawyers, 2000-2005 · "M&A in the Non-Stock, Nonprofit World: Tax-Exempt Bond Concerns-Questions and Musings," Journal of Taxation of Investments, vol. 17 no. 2, Winter, 2000 · Federal Taxation of Municipal Bonds (ed.), 1994-1998 · "Arbitrage and Rebate Considerations," Tax-Exempt Financing, Practicing Law Institute, 1993-1995 · "Rebate and Exceptions to Rebate," Bond Attorneys' Workshop, National Association of Bond Lawyers, 1993-1994 · "Exceptions to Rebate," Arbitrage, National Association of Bond Lawyers, 1992 · "Exceptions to Rebate," Bond Attorneys' Workshop, National Association of Bond Lawyers, 1992 · "Introduction to Arbitrage and Rebate," Tax-Exempt Financing, Practicing Law Institute, 1989-1992 · Arbitrage 1987 (ed.), National Association of Bond Lawyers, 1987 · Panelist, Bond Attorneys' Workshop, National Association of Bond Lawyers, 1983-present · Panelist, Tax and Securities Institute, National Association of Bond Lawyers, 1989-present · Lecturer, Fundamentals of Municipal Bonds, National Association of Bond Lawyers, 1985-2006 Professional Affiliations · Citizen Budget Commission, Trustee, 2009-present · American Bar Association, Committee on Government Submissions, Member, 1999-present; Committee on Tax-Exempt Financing, Former Chair, 1998-1999 · New York State Bar Association, Member, 2005-present; Committee on Tax-Exempt Finance, Former Chair, 1991-2005 · Northeast Women in Public Finance, Board Member, 2008-present; Secretary, 2010-present · Georgetown University Law Center, Board of Law Alumni, 1991-1996 · National Association of Bond Lawyers, Member; Treasurer, Board Member, 1999-2000 · American College of Bond Counsel, 2001-present Outside Interests · Roundabout Theater, Leadership Council, August 2008-present · Court Appointed Special Advocates (CASA), Board of Directors, 1989-present; Former President, 1997-2002 Awards and Achievements · 2011 Encore Award, Arts & Business Council of New York, Creative Business Volunteer |