Profile

Michael Larsen focuses his practice on the tax issues related to public finance transactions. Mr. Larsen has extensive experience in a wide variety of public finance transactions, having served as bond counsel, underwriter’s counsel, borrower’s counsel and special tax counsel on financings for, among other entities, state and local governments, cultural institutions, public and private universities, hospital systems, water and sewer authorities, and single family and multi-family housing authorities.

Mr. Larsen has written and lectured extensively on the tax aspects of public finance transactions, recently serving as co-chair of a panel of the National Association of Bond Lawyers providing comments to the Treasury Department and the IRS on reissuance standards for tax-exempt bonds. Before joining Parker Poe, Mr. Larsen was a senior associate in the tax department of an international law firm.

Experience Highlights

Mr. Larsen has represented:

• A large NY issuer in the issuance of nearly $1 billion of pooled school district bonds
• Numerous issuers of tax-exempt bonds secured by settlement payments under the Master Settlement Agreement between the states and tobacco companies
• A toll road developer in one of the largest issuances of qualified highway bonds undertaken to date
• As bond counsel and special tax counsel, one of the largest public utilities in the country in numerous financings involving complex derivative structures, including several “super-integrated” municipal swaps
• A client facing Internal Revenue Code Section 6700 penalties before the IRS
• Numerous clients on audits before the IRS, and has obtained favorable private letter rulings for several unique financing structures
• Numerous clients in financings in the Carolinas, New York, California and the District of Columbia
• Numerous clients in municipal derivatives, including swap transactions and interest rate caps

News

• Parker Poe Names Four New Partners
  January 5, 2010
• Michael Larsen Joins the Parker Poe Public Finance Group
  July 14, 2008

Events & Speaking Engagements

• Post-Issuance Tax Compliance Related to Financing with Tax-Exempt Bonds
  August 2008
  North Carolina Healthcare Financial Management Association Conference

Publications

Co-author, "New Schedule K to IRS Form 990 Imposes an Increased Burden on Hospitals with Tax-Exempt Debt," Tarheel News, Winter 2009

Co-author, “An Explanation of Clean Renewable Energy Bonds,” Tax Notes, Vol. 110, March 6, 2006

Memberships

• Federal Taxation of Municipal Bonds
  2009 Editorial Board