Overview

Municipal/Public Finance

Rion Foley's primary practice area is in public finance and structured finance with investment bankers and all types of issuers and their programs. Rion has served as bond counsel, disclosure counsel, underwriter’s counsel, placement agent counsel, issuer’s counsel, trustee’s counsel, and credit enhancer’s counsel in virtually every area of both tax-exempt and taxable public finance. Rion also represents banks and other providers of letters of credit, liquidity facilities, standby bond purchase agreements and direct placements relating to publicly and privately sold bonds. Rion’s practice experience relates to a number of public, nonprofit and for-profit corporate entities, including but not limited to municipalities, hospitals, educational institutions, school districts, public agencies, housing authorities, student loan authorities, infrastructure bank transportation agencies, public utility authorities, port facility authorities, airport facility authorities and other state and local governmental bodies.

Federal Tax

Rion has experience in federal tax matters in helping clients with creative tax efficient strategies for expansion, ownership succession, mergers and acquisitions, tax-exempt organizations, real estate transactions and other matters. Rion’s primary federal tax practice area is expertise in Section 103 tax issues, especially arbitrage, refundings and private activity bonds. He is responsible for delivering tax opinions in all areas of tax-exempt finance and handles tax controversy representation in audits of outstanding bond issues by the Internal Revenue Service. Rion also represents the 529 qualified tuition program in the state of North Carolina where he assists in the development of authorizing legislation and program rules, in contract negotiation and program documentation, and in tax and disclosure matters.

Economic Development/State and Local Tax

Rion’s other primary practice area is advising clients on, and negotiating economic development incentive packages for, clients locating or expanding in South Carolina. Sample incentives include fee-in-lieu-of-tax transactions, special source revenue bonds, infrastructure tax credits, pollution control facilities, multi-county industrial/business parks, jobs tax credits and job development credits. The incentive packages are handled for both industry and government.