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 also has extensive experience in multistate tax issues and Ohio state and local tax issues. His expertise extends to both public sector clients, where he has advised many Ohio cities on municipal income tax issues and has drafted their municipal income tax ordinances, and to private sector clients. He has counseled such clients in transactional matters, controversies, obtaining rulings from the Ohio Department of Taxation and seeking changes in law, including drafting legislation that was enacted by the Ohio General Assembly.
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.