Jean S. Everett

Of Counsel

Philadelphia

Tel 215.864.8706
Fax 215.864.8999

New York

Tel 646.346.8017
Fax 212.223.1942

Jean Everett is an experienced finance attorney who focuses on tax and related aspects of public finance transactions involving tax-exempt and taxable bonds, tax credits, and other government subsidies for significant social infrastructure projects. She has decades of experience analyzing and advising on transactions in which bond interest is eligible to be excluded from income of the holders under Section 103 of the Tax Code. She assists issuers, 501(c)(3) borrowers, and other conduit borrowers with responses to IRS examinations of bond transactions.

Jean has served as bond counsel, underwriter’s counsel, bank counsel, or developer’s counsel in numerous high-value projects over more than two decades, gaining insight into managing transactions, teams, and closings, including when parties are fully or partially remote. She has represented state finance authorities, for housing and higher education projects, as well as industrial development agencies, local development corporations, and municipal issuers of general obligation bonds in transactions that have produced major facilities for public benefit.

Services

Experience

Representative Matters

Advised local nonprofit on joint venture with public housing authority and master developer on proposed Purpose-Built redevelopment of approximately 1,100 units of new and rehabilitated housing to replace deteriorated public housing units on four sites, and creation of a new neighborhood with many amenities including wellness and educational facilities
Represented regional bank in direct purchase of tax-exempt revenue bonds to refund tax-exempt bonds issued to finance a 150-unit continuing care retirement community secured by a mortgage, revenue pledge, and parent company guaranty
Represented nonprofit sponsor, managing member, and owner entity in development and financing of a 50-unit affordable residential rental project with 30 units for individuals recovering from serious mental illness, involving 4 percent LIHTCs, tax-exempt revenues bonds, a subordinate taxable mortgage loan, and a construction-period letter of credit, along with state-funded permanent credit enhancement and capital and operating subsidy

Served as bond counsel to the New York State Housing Finance Agency and performed tax review under Code Section 103 in issuance of $68.88 million in Affordable Housing Revenue Bonds, 2018 Series B (Climate Bond/Certified Green Bonds) and $19 million in Affordable Housing Revenue Bonds, 2018 Series C, to finance construction or renovation of three qualified residential rental projects
Served as bond counsel to the Dormitory Authority of the State of New York and performed tax review and analysis under Code Section 103 in issuance of $16.19 million in Inter-agency Council Pooled Loan Program Revenue Bonds to finance facilities for the developmentally disabled, owned and operated by six not-for-profit service providers
Served as underwriter’s counsel for Madison County (N.Y.) Capital Resource Corporation Taxable Revenue Bonds (Colgate University Refunding Project), Series 2019
Served as underwriter’s counsel for City of Albany (N.Y.) Capital Resource Corporation Tax-Exempt Revenue Bonds, (Albany Leadership Charter High School for Girls Project), Series 2019
Served as bond counsel to City of Syracuse (N.Y.) Industrial Development Agency in issuance of School Facility Revenue Bonds (Syracuse City School District Project) to finance and refinance Phase II of comprehensive redevelopment program for the school district, issued in transactions from 2018 to 2021
Advised developer on liquidation of equity interests in various joint ventures
Represented regional bank in amendment of various credit facilities in connection with phase-out of LIBOR
Advised several developers on formation of Qualified Opportunity Funds and Qualified Opportunity Zone Businesses
Served as counsel to developer in establishing a Qualified Opportunity Fund and offering equity interests in the fund for indirect investment in a business constructing and operating a mixed-use project
Served as counsel to family-owned business operating in seven states on inter-family sale of stock of operating entity and membership interests in real property owner entities
Represented closely held family company on sale of line of business and related assets
Represented individual owners in sale of municipal services company operating in 48 states

Professional Highlights

Professional Activities

National Association of Bond Lawyers

Speaking Engagements

Presenter, Enhancements to Opportunity Zone Incentives, CenterStates CEO, March 2020

Presenter, Opportunity Zones Program, CenterStates CEO, July 2019

Presenter, “Public/Private Development Partnerships,” Lorman Education Services, December 2004

Publications

Author, “Aging Infrastructure and Unemployment: The Erie Canal and WPA,” white paper, July 2020

Author, “Private Activity Bonds Repeal – The True Cost of Tax Reform,” Buffalo Law Journal, December 2017

Co-author, “Impact of Tax-Exempt Bond Rules on Alternate Uses of School Facilities,” The Reporter, New York State Association of School Business Officials, Summer 2014

Co-author, “The Case of Gibson Plaza: Preserving Affordability in the Nation’s Capital,” Journal of Housing and Community Development, June 2011

Related Insights

Credentials

Education

Suffolk University Law School (J.D., cum laude, 1988)

Cornell University (B.A., with distinction, 1980)

Admissions

Pennsylvania