Vicky Tsilas

Tel 202.661.7694
Fax 202.661.2299
Washington, DC

Vicky Tsilas focuses on the tax aspects of tax-exempt and tax-credit bond transactions and issues related to tax exempt organizations. She represents nonprofit organizations as borrowers and state and local governments as bond counsel in tax-exempt bond financings. She also has extensive experience representing clients in IRS audits of tax-exempt bond financings involving hospital systems, universities, and solid-waste and sewage facilities.  In addition to her private practice experience, Vicky has served in the highest legal positions overseeing tax-exempt bonds at the U.S. Treasury Department and IRS. Vicky also has been in involved in New Market Tax Credit financings representing different parties in the transactions.

Vicky advises a wide range of nonprofit clients including colleges, universities, hospitals, and foundations, as well as various public charities, on tax exempt organization issues ranging from unrelated business income to joint ventures between nonprofit and for-profit entities and post-issuance compliance responsibilities. She is a frequent contributor to "The Exempt Organization Tax Review" and has been a speaker at the Georgetown University Exempt Organization Conference.

Before rejoining Ballard Spahr as a partner in 2018, Vicky was Branch Chief of the Tax-Exempt Bond Branch for Financial Institutions and Products at the IRS, where she supervised the team of attorneys who provide regulatory guidance—including issue price and public approval regulations—and private letter rulings.

Vicky served as an attorney-adviser to the Honorable Laurence J. Whalen of the U.S. Tax Court in Washington, D.C., from 1997 to 1999. She first joined Ballard Spahr in 1999 as a tax associate and became a partner in 2015. In between, from 2012-2015, she served as an attorney-adviser in the Office of Tax Policy at the U.S. Treasury Department, where she oversaw the development and review of IRS regulations and guidance involving tax-exempt and tax credit bond financings. She also advised Treasury officials on the formulation of U.S. policy on tax-exempt, public-private partnerships, and tax credit bond transactions, and worked closely with Congress on legislative matters involving tax-exempt bonds.

Her experience also includes serving as Assistant Branch Chief in the Tax-Exempt Bond Branch for Financial Institutions and Products at the IRS. In that role, she worked on regulations governing payments in lieu of taxes, guidance on provisions related to research agreements, proposed regulations involving practice before the IRS (Circular 230) as they relate to tax-exempt bonds, final remedial action regulations, and arbitrage-related matters. She also was Chief Counsel representative to the Tax-Exempt Bond Focus Group, which provides recommendations to IRS agents dealing with complicated tax-exempt bond issues.

Pro Bono Experience

Vicky has served on Ballard Spahr’s Pro Bono Committee and is a recipient of the Ballard Spahr Pro Bono Award for Outstanding Legal Services to the Poor.

Professional Activities

American Bar Association, Tax Exempt Financing Section

National Association of Bond Lawyers (NABL)

District of Columbia Bar Association

New Jersey State Bar Association

New York Bar Association

Recognition & Accomplishments

Chief Counsel Performance Award 2017

Treasury Department Performance Award, 2013

Chief Counsel Performance Award, Tax-Exempt Bond Focus Group, 2005

Ballard Spahr Pro Bono Award for Outstanding Legal Services to the Poor


Co-author, "Bond Relief Amid COVID-19 Restrictions: Telephonic Public Hearings and Enhanced Issuer Ability to Purchase Bonds," Ballard Spahr alert, May 5, 2020

Co-author, "Is Your Organization Tax-Exempt in D.C.? Act Soon to Retain the Exemption!" Ballard Spahr alert, March 12, 2019

Co-author, "Tax-Exempt Bond Community Considers New Bond Regulations," Ballard Spahr alert, January 16, 2019

Co-author, "ABC's of Arbitrage," American Bar Association, 2018

Co-author, "New IRS Management Guidance is Flexible, Furthers P3s," Ballard Spahr alert, August 25, 2016

Co-author, "P3 Projects and Tax-Exempt Bond Financing: How Does the Puzzle Work?" Municipal Finance Journal, Vol. 37, No. 1, 2016

Co-author, "Why Your Organization Should Care About the Final Allocation and Accounting Regulations for Bond Financed Facilities," The Exempt Organization Tax Review, Vol. 77, No. 4, April 2016

Co-author, "IRS Issues Final Allocation and Accounting Regulations," American Health Lawyers Association alert, October 2015

Co-author, "New Rules Encourage Use of P3s," Ballard Spahr alert, November 20, 2015 

Co-author, "Where We Stand on Issue Price for Tax-Exempt Bonds," Ballard Spahr alert, November 9, 2015 

Co-author, "Bill Would Create New Category of Tax-Exempt Bonds, Tax Credits for P3 Projects," Ballard Spahr alert, May 6, 2015

"Keeping Up With the Times: An Ever-Changing Tax-Exempt Bond World," 75 Exempt Org. Tax. Rev. 1, May 2015

Co-author, "Obama's Proposed 2016 Budget Seeks to Address Infrastructure Needs," Ballard Spahr alert, February 6, 2015

Co-author, "Recent Favorable IRS Guidance for Tax-exempt Bond Financed Facilities," Ballard Spahr alert, February 2, 2015

Co-author, "President Announces New Build America Initiatives; Introduces New Type of Municipal Bond," Ballard Spahr alert, January 21, 2015

Contributing writer, Exempt Organization Tax Review (Letter Ruling Alerts), 2008-2010

"Understanding the Basics: A Primer on the Tax-Exempt and Tax Credit Bonds Provisions in ARRA," 64 Exempt Org. Tax Rev. 3, 2009

"Things You Need To Know About Schedule K of Form 990," 63 Exempt Org. Tax Rev. 298, 2009

"Sierra Club Inc. v. Commissioner: Why Is the IRS Continuing to Fight a Losing Battle?" 24 Exempt Org. Tax Rev. 487, 1999

"Whole Hospital Joint Ventures – Do Exempt Organizations Really Know What They’re Getting Themselves Into?" 17 Exempt Org. Tax Rev. 241, 273, 1997

Contributing editor, Tax Notes – A Tax Baedeker, A Guide to the 1996 Changes

Speaking Engagements

Vicky is a frequent speaker at the annual NABL Bond Attorneys' Workshops, NABL Tax and Securities Law Institute and ABA Tax-exempt Financing Section meetings. Her recent speeches include:

Steering Committee member and Chair of IRS Enforcement Panel, National Association of Bond Lawyers, The Workshop, September 2019

"Tax Hot Topics," Pennsylvania Bond Lawyers Annual Seminar, May 2019

"Legislative Update Panel," TEGE Council Meeting 2019

"Recent Bond Developments," American Health Lawyers Association Annual Tax Meeting 2018

"Section 147(f) Public Approvals," NABL University Online Course

"IRS Enforcement," National Association of Bond Lawyers, Bond Attorneys Workshop, September 26-28, 2018

"Legislative Panel Update," American Bar Association, Tax-Exempt Financing Committee, May 2018

"Hot Tax Topics," National Association of Bond Lawyers, Tax & Securities Law Institute, February 22-23, 2018

"Management Contracts," American Health Lawyers Association, Tax Issues for Health Organizations, October 19, 2017

"Hot Tax Topics," National Association of Bond Lawyers, Bond Attorneys Workshop, October 4-6, 2017

"Tax-Exempt Bond Developments," American Health Lawyers Association, June 27, 2017

"Legislative Panel Update," American Bar Association Tax-Exempt Financing Committee, May 12, 2017

"Tax-Exempt Bond Development," Georgetown University, Representing and Managing Tax-Exempt Organizations Conference, April 27-28, 2017

"Hot Tax Topics," National Association of Bond Lawyers, Tax & Securities Conference, March 9-10, 2017

"What You Need to Know Before Drafting Your Next Management Contract," American Health Lawyers Association, December 13, 2016

"Final Allocation and Accounting Regulations for Tax-Exempt Bonds," American Health Lawyers Association, October 19-21, 2016

"What's Up in Tax-Exemption and Financing for Hospitals: News Everyone Needs to Know," American Health Lawyers Association, Annual Meeting, Denver, June 27-29, 2016

"Recent Bond Developments" panel, Georgetown Law Continuing Legal Education, Representing and Managing Tax-Exempt Organizations, April 28-29, 2016

"Tax-exempt Issues for Nonprofit Entities" panel, ABA Affordable Housing & Community Development, 25th Annual Housing Meeting, May 26, 2016  

Panel Chair, New Money Financings, National Association of Bond Lawyers Tax & Securities Law Institute, March 2016 

"Understanding the Final Allocation and Accounting Regulations," Ballard Spahr webinar, December 16, 2015 

"Tax Issues for Healthcare Organizations,"American Health Lawyers Association, October 7-9, 2015 meetings

"Due Diligence" and "Intermediate Arbitrage" panels, National Association of Bond Lawyers, Bond Attorneys Workshop, September 9-11, 2015

"Tax Code Update," Pennsylvania Association of Bond Lawyers, 26th Annual Seminar, May 21, 2015

"Tools for Economic Development," American Bar Association Tax Section Meeting, May 8, 2015

"Update on 501(c)(3) Bonds," Georgetown University Law Center Continuing Legal Education: Representing and Managing Tax-Exempt Organizations, April 23-24, 2015

"Hospitals and Health Systems – Update on Recent Regulatory Guidance," Ballard Spahr webinar, April 16, 2015

"Reissuance of Tax-Exempt Bonds," National Association of Bond Lawyers, Tax & Securities Institute, March 5, 2015

"Recent IRS Developments Affecting Educational Institutions and the New Management Contract Safe Harbor," Ballard Spahr webinar, February 27, 2015

"Developments in Tax-Exempt Bond Financing," Pennsylvania Bar Institute, 21st Annual Health Law Institute, February 2015

Treasury representative: "Strengthening Tribal Economies: Economic Development in Indian Country," White House Tribal Nations Conference 2013

Georgetown University Law Center (LL.M. Taxation)
Editorial Staff, Tax Notes magazine

Fordham University School of Law (J.D.)
Staff Member, Fordham Environmental Law Reporter
Recipient, Moore McCormack Award
Editorial Assistant, Lloyd's Maritime Newsletter

Bryn Mawr College (B.A.)
Dana Internship and MacArthur Grant


Fluent in Greek and French

District of Columbia

New Jersey

New York