Arbitrage Rebate Services

Hawkins Delafield & Wood LLP ("Hawkins") has provided arbitrage rebate and yield restriction compliance services ("Arbitrage Services") to public finance clients since 1982, when the arbitrage rebate requirements first became applicable to certain tax-exempt bonds.

Our Arbitrage Services are provided through a separate in-house arbitrage compliance group, the Financial Analysis & Services Group, or “FAS,” that employs professionals with finance, mathematics, statistics and engineering backgrounds. FAS devotes 100 percent of its time to providing arbitrage rebate and yield restriction services and financial structuring services. The senior members of FAS have, on average, over 30 years of experience in providing Arbitrage Services

Our FAS Group works closely with our tax attorneys and performs the entire range of calculations that are necessary for tax-exempt and tax-advantaged bonds, including arbitrage rebate, yield restriction and financial structuring services. The relationship between the quantitative and legal experts of the firm enables us to comprehensively and efficiently undertake complex analyses.

As a premier arbitrage rebate provider, FAS:

  • Has prepared over 30,000 arbitrage compliance reports with tax opinions.
  • Has over 5,000 bond issues under contract.
  • Prepares annually over 1,000 arbitrage compliance reports.
  • Has experience working with large sophisticated issuers.
  • Maintains close relationship with the IRS agents and managers.
  • Has worked on many IRS audits, examinations and inquiries with favorable outcomes.

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We have rendered arbitrage rebate compliance services for all types of transactions and have addressed virtually all tax and methodology issues relating to rebate. As part of our arbitrage rebate compliance services, we consider various elective and computational options available under the tax regulations in an effort to reduce the rebate liability of the client. We are at the “top of the learning curve” on developing solutions to arbitrage related issues, while many other firms have yet to address or even identify them. Our comprehensive services (e.g., preparation of IRS forms and advice on maintenance of proper records) are designed to minimize the administrative burden on clients. Our services can be tailored to the specific needs of clients. Our services include the following:

  • Arbitrage rebate analysis
  • Yield restriction analysis
  • Private use calculations
  • Arbitrage consultation on new issue structures
  • Projected rebate and yield restriction liabilities
  • Review of in-house arbitrage rebate calculations
  • Penalty in-lieu-of rebate analyses
  • Defeasance Analysis
  • Escrow and Refunding Analysis
  • IRS examination, audit and refund assistance
  • Refund claims for arbitrage rebate overpayments
  • Preparation of the IRS Form 990 (Schedule K)
  • Review of structured investment products and hedges
  • Review of record keeping systems
  • Est. 1854

    For More Than 165 Years, Hawkins Has Maintained a Reputation for Excellence, Timeliness, Discretion and Ethical Services

  • 30,000+

    Arbitrage compliance reports performed and verified with tax opinions