New Market Tax Credits_Kutak Rock LLPTHE CITY OF DUBUQUE
Masterpiece on the Mississippi
Dubuque
All-American City
2007
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: New Market Tax Credits
DATE: November 25, 2008
In conjunction with the City's contract with B & G Development, LLC to assist the City in
efforts to obtain New Market Tax Credit funding for City projects, Economic
Development Director Dave Heiar is recommending execution of a contract with Kutak
Rock, LLP for legal advice associated with securing New Market Tax Credits.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
Michael C. Van Milligen
MCVM/jh
Attachment
cc: Barry Lindahl, City Attorney
Cindy Steinhauser, Assistant City Manager
David J. Heiar, Economic Development Director
THE CITY OF DUBUQUE
Masterpiece on the Mississippi
Dubuque
All-American City
2007
November 21, 2008
TO: Michael C. Van Milligen, City Manager
FROM: David J. Heiar, Economic Development Director
RE: New Market Tax Credits
INTRODUCTION
The City Council has authorized City Staff and consultants to pursue New Market Tax
Credits (NMTC) for various local development projects. The use of NMTC funding is
very complicated and will require the City to assemble a team of specialists to help
guide this process.
BACKGROUND
In September, the Council approved a contract with B & G Development, LLC
(Gronen/Butler) to assist the City in our efforts to obtain NMTC funding for City projects.
Since that time, Gronen and Butler have attended a national conference for Certified
Development Entities (CDE) that have received NMTC allocations. Based on their
efforts, two CDE's have been to Dubuque to witness some of our re-development efforts
in the Port of Dubuque, Downtown and Warehouse Districts. Both CDE's have
expressed a strong interest in working with the City to help fill some of the financing
gaps.
As we move closer to putting together financing packages, we will need to add other
consultants to our team to assure that we are meeting all the federal regulations that are
part of the NMTC process. It is also important that we include team members who are
very familiar with and have a good working knowledge of the NMTC process. At this
time we need the assistance of a legal firm that specializes in NMTC. Gronen and Butler
have recommended Kutak Rock, LLP of Kansas City, based on their national reputation.
Bill Noth, Dubuque's bond counsel, has worked with Kutak Rock, LLP on NMTC deals
in other Iowa cities. He has had very favorable experiences with this firm.
At this time we are not sure how much legal consultation will be required. Therefore, at
least until we can be more specific about our projects, Kutak Rock, LLP is proposing an
hourly fee on an as needed basis (see attached agreement and resumes).
RECOMMENDATION/ACTION STEP
That the City Council approve a contract with Kutak Rock, LLP for legal advice
associated with securing New Market Tax Credits on an as needed basis.
F:\USERS\DHeiar\NMTC\Kutak Rock Council Memo.doc
KUTAK ROCK LLP
ATLANTA
CHICAGO
SUITE 500 DENVER
1010 GRAND BOULEVARD DE9 MOIN EB
FAY ETT EYILLE
KANSAS CITY, MISSOURI 84108-2220
IRVINE
816-960-OOSO LITTLE ROCK
L03 ANO ELE9
FACSIMILE 816-980-0041
OKLAHOMA CITY
www.kutakrock.com OMAHA
RICHMOND
SCOTTSDALE
Q
October 22, 2000 WICHITA TON
Mr. David Heiaz
City of Dubuque, Iowa
50 West 13~' Street
Dubuque, IA 52001
Re: Engagement Letter re: Representation of City of Dubuque, Iowa (the "City") in
planning, structuring and implementing a new markets tax credit ("NMTC") transaction
relating to a community stadium (the "Transaction")
Dear Mr. Heiar:
At the beginning of any engagement with a client, it is our practice to prepare a letter
setting forth the terms of our engagement, including our fees and expenses. Attached to this
letter are the terms and conditions of representation. Until a CDE issues a commitment letter to
provide new market tax credit allocation authority with respect to the Transaction, you agree to
pay our accrued fees and expenses on a monthly basis within 30 days of your receipt of an
invoice. Thereafter, we will not submit monthly invoices but our accrued fees and expenses
shall be due and payable at the closing of the Transaction, although we reserve the right bill you
for our fees and expenses incurred to date if the Transaction has not successfully closed before
August 1, 2009.
We have listed our hourly rates for work on the Transaction on the fee and expenses
Schedule attached hereto.
Please acknowledge the terms of our representation by executing the signature block
below. We appreciate the opportunity to be of service to you.
Very truly yours,
Paul . O' o
4829-3163-3154.2
KUTAK ROCK LLP
Accepted and agreed to this day of October, 2008.
CITY OF DUBUQUE, IOWA
By: _
Name:
Title:
4829-3163-3154.2
KUTAK ROCK LLP
KUTAK ROCK LLP
TERMS OF REPRESENTATION
Kutak Rock LLP is pleased to have this opportunity to serve you. Our goal is to provide
you quality legal services on a prompt, effrcient basis. We believe that our relationship will be
stronger and more effective when there is a clear understanding of the services we will perform,
the fees we intend to charge for such services and the payment thereof. Therefore, it is our
standard procedure to be specific with our clients as to the scope of the services that we intend to
provide and the terms by which we will bill fees and expenses. The letter accompanying these
Terms of Representation sets forth that information. If what is set forth in the accompanying
letter or in these Terms of Representation does not accurately describe your understanding of the
services we are to perform or the terms for billing fees and expenses, please advise the attorney
sending you the letter. Unless the attorney sending the engagement letter to you is notifred
promptly, we will assume that these Terms of Representation and the accompanying letter are
acceptable to you.
Scope of Representation. The scope of our representation will be limited to providing
only those services that are described in the accompanying letter. Unless otherwise noted, we
will render those legal services that are necessary to the representation. No other services are
intended to be provided without the mutual agreement of you, as our client, and Kutak Rock
LLP. Later, if you determine to change materially the scope of our representation, we will need
to document that in additional correspondence.
Fees and Hourly Rates. Our fees are based primarily on the time spent by each attorney
and paralegal in the firm who work on your matter. The hourly rate of each attorney and
paralegal is based on that individual's expertise and experience. We reserve the right to adjust
our fee rates on an annual basis, and bills for our fees will reflect those adjustments. We
normally record time in six-minute intervals for work done on your matter, including required
travel time.
Expenses. Our charges for expenses that we incur on this transaction are included in the
fee quote included with the enclosed letter. We will bill you for expenses we incur on your
behalf. We will ask you to pay directly any significant outside expenses incurred on your behalf
and will direct statements for such expenses to you for payment. All expenses will be itemized
on the statements we will send you.
Schedule. Attached is a current Schedule of our fees and expense charges.
Attorney-Client Privilege. Our statements may contain information protected by the
attorney-client privilege. As the privilege could be deemed waived if someone other than the
client sees the privileged material, we recommend that you keep our statements, as well as other
letters and communications from us, in a separate file marked "Attorney-Client Privileged
Materials" and keep the file in a secure place. Your communications with us are legally
protected by the attorney-client privilege. In addition, we will treat your matter as confidential,
and we will not (unless you specifically grant us the authority to do so) discuss or otherwise
4819-3163-3154.2
KUTAK ROCK LLP
make available to anyone, including other clients, any information about you, your business or
our work on your behalf.
Termination of Services and Representation. You may terminate our services at any
time. Termination of our representation does not, however, relieve you from the responsibility
of paying those fees and expenses incurred through the date we are notified of such termination.
Similarly, we may withdraw from this representation for reasons including your failure to timely
pay our statements; failure to disclose all facts material to our representation; failure to act in
accordance with our advice; or development of one or more circumstances which, in our
judgment, impair our ability to maintain an effective attorney-client relationship.
Completion of Matter. After a particular matter is completed, we do not (unless you
specifically request in writing that we do so) undertake to continue to review that matter and
update you concerning legal developments, such as changes in applicable laws or regulations. If
you do ask us to review a specific matter on which we have previously worked, we will consider
that to be a new representation. Thus, while we may, from time to time, call to your attention
issues or legal developments that might be relevant to your operations, we are not undertaking to
do so as a part of this representation. Unless otherwise terminated, our representation will end
upon our sending you our final statement for services rendered with respect to this matter.
Document Retention. If, upon termination or completion of a matter, you wish to have
your documents in our possession delivered to you, please advise us. Otherwise, all such
documents will be stored for a reasonable amount of time and will thereafter be destroyed in
accordance with our established policy.
No Guarantee. We will perform our professional services on your behalf to the best of
our ability, but we cannot make and have not made any guarantees regarding the outcome of our
work on your matters. Any expressions by us about the outcome of your matters are our best
professional views only and are limited by our factual knowledge at the time they are expressed.
We hope this explanation is helpful to you, and we invite you to discuss any concern with
us at any time or to enquire at any time about the fees or costs incurred. It is extremely
important that we proceed so that you and we have a clear and satisfactory understanding about
the work to be performed. We will strive to keep you fully informed during the course of this
engagement and anticipate that you, likewise, will keep us informed of pertinent developments.
We trust that you will find that we are not only available and responsive but that we will work
diligently to meet your needs and deadlines.
4829-3163-3154.2
KUTAK ROCK LLP
SCHEDULE
DESIGNATED HOURLY RATES
Paul O'Hanlon
Daniel J. Skomal
Jeff Arnold
Kathy Giancana
HOURLY RATES
Other Partners
Other Associates
Pazalegals
DISBURSEMENTS
Facsimiles
Outgoing -local
Outgoing long-distance
Reproduction Costs
Computer research
Long distance
Overtime
Postage
Other expenses such as messenger,
filing fees, publication fees, travel,
etc.
$350
$325
$275
$350
$175 to $400
$110 to $225
$40 to $85
$.50 per page
$1.00 per page
$.10 per page
Direct cost
Direct cost
Direct cost
Direct cost
Direct cost
4829-3163-3154.2
KuTnK Rocx LLP
New Markets
Tax Credits Practice
August 2008
4836-8470-6562.1
KUTAK ROCK LLP
L NEW MARKETS TAX CREDIT PRACTICE
With one of the most active new markets tax credit (NMTC) practices in the country,
Kutak Rock LLP is a recognized industry leader in this area of law.
NMTCs are a financial incentive created to assist in attracting capital investments to
distressed census tracts. As provided by legislation, the Community Development Financial
Institution Fund (CDFI Fund), a branch of the United States Treasury Department, makes
available a block of credits for community development projects. Entities that receive
certification as qualified community development entities (CDEs) apply for the credits in a
competitive process. NMTCs attract investors to community development projects by providing
tax credits to investors over aseven-year period following initial investment.
Kutak Rock LLP has developed a substantial NMTC practice through its representation
of investors, leverage fund lenders, CDEs and qualified active low-income community
businesses (QALICBs). In addition to our client representation, lawyers at Kutak Rock LLP
actively participate in industry efforts to resolve tax and structuring issues in the NMTC area,
including through submitting formal comments to the CDFI Fund and the Treasury Department
and through industry efforts to promote uniformity among practitioners.
The firm regularly represents one of the most active leveraged fund lenders and
structuring agents in the NMTC industry on its NMTC transactions. In our role as its counsel,
the firm is responsible for preparing all of the major documentation for each transaction,
including the leveraged fund operating agreement, the CDE operating agreement, the leveraged
fund loan agreements, the QLICI loan agreements, the loan servicing and origination
agreements, the fee agreements and various related documents. The firm also delivers the major
tax opinions to the leveraged fund lender and the tax credit equity investor in these transactions.
The firm represents some of the major equity investors throughout the country with
respect to structuring the qualified equity investments (QEIs) into CDEs. In this regard, the firm
has participated in both leveraged, non-leveraged transactions and transactions combining the
NMTC with historic rehabilitation tax credits. In the scope of such representation, the attorneys
in the firm have been actively involved in structuring and negotiating the leverage fund and CDE
operating agreements, servicing and management agreements, guarantees and related ancillary
documentation as well as the review of the necessary due diligence. The firm has delivered the
customary tax opinions with respect to the availability of the NMTCs and significant tax issues
to the Investor.
4836-8470-6562.1
In addition, the firm represents equity investors with respect to qualified equity
investments (QEIs) into CDEs, CDEs that have received NMTC allocation who are receiving
QEIs from investors and QALICBs with respect to qualified low income community investments
from CDEs. The firm has also represented CDEs in connection with applications for allocations
of NMTCs as well as applications for CDE status. Finally, the firm has representing QALICBs
that are receiving QLICIs from CDEs.
Through its participation in a broad range of NMTC transactions having varied
structures, Kutak Rock has obtained a broad range of experience on a variety of structures and
the often complicated tax and business issues associated with NMTC transactions. Kutak Rock
has developed innovative structures for its clients in NMTC transactions, including structures
which provide the benefits of using tax-exempt financing in connection with realizing NMTCs,
as well as revolving loan structures within the framework of NMTC transactions.
The resumes of Kutak Rock LLP's principal partners and associates who would provide
any requested services are attached hereto as Attachment A. We believe that the attorneys listed
in Attachment A possess the necessary technical skills and experience level with respect to the
new markets tax credit program and complimentary areas such that Kutak Rock LLP can achieve
the objective of efficiently and effectively completing proposed engagements at a competitive
cost.
4836-8470-6562.1
in both structured and project finance transactions. Mr. Arnold is admitted to practice in Missouri
and Texas.
Kathleen Giancana represents businesses and individuals in a broad range of complex federal,
state, local and foreign tax matters. Her specific areas of expertise include new markets tax credit
transactions, the structuring and operation of partnerships, limited liability companies and other
joint ventures, international taxation, mergers and acquisitions, corporate formations, the
preservation of net operating loss carryovers, leveraged leasing, financial products, tax shelters
and Arizona taxes. Ms. Giancana also provides estate planning for high-net-worth individuals,
including the implementation of sophisticated wealth transfer strategies designed to minimize
gift, estate, generation-skipping and income taxes. Ms. Giancana has an active tax controversy
practice, which includes litigating in tax courts, representing taxpayers in connection with federal
and state tax audits and obtaining private letter rulings from the Internal Revenue Service and
state and local taxing authorities. Ms. Giancana spent the first 17 years of her career practicing
on Wall Street. She is admitted to practice in Arizona and New York.
4836-8470-6562.1