Joy Ellis (formerly Joy Bode) has been a tax partner since 1989. Her practice is focused on complex tax-exempt financings by governmental and conduit borrowers, as well as general tax matters relating to tax-exempt organizations, such as representation of hospitals, nonprofit housing corporations, universities, private foundations and large health care systems. In addition, she counsels on business tax matters and tax controversies, including the representation of large taxpayers in audits before the Internal Revenue Service.
JD, cum laude, Harvard University Law School, 1979
AB, Criminology, summa cum laude, the University of California at Berkeley, 1975
Joy was admitted to practice law in Texas in 1979.
From 1979 to 1981, she was a judicial clerk to Judge Richard C. Wilber on the United States Tax Court.
Recent matters include:
- Representing five major hospital systems in restructuring several billion dollars of tax exempt debt, due to market turmoil as well as a favorable interest rate environment
- Representing large cities and other issuers in connection with interest rate swaps and other derivatives
- Successfully defending cities, counties, school districts, hospitals and other issuers and conduit borrowers in at least thirty IRS audits of tax-exempt bonds in the last ten years, all resulting in no change or adjustment to the tax-exempt status of the bonds
- Successfully defending a Fortune 100 software company before the IRS on issues concerning acquisitions and cross border leases, saving the company in taxes, penalties and interest
- Obtaining complex letter rulings from the IRS for a major Texas city regarding the use of reserve fund monies and payments for water capacity, which saved the city debt service payments on its tax exempt bonds
Rankings and recognitions
- Legal 500 US, recommended lawyer, US taxes - non-contentious, The Legal 500, 2016
- Legal 500 US, recommended lawyer, Tax: Domestic, The Legal 500, 2012 - 2015
- Legal 500 US, recommended lawyer, Healthcare, The Legal 500, 2013
- Texas Top Rated Lawyer, LexisNexis Martindale-Hubbell, 2012 - 2013
- The Best Lawyers in America, Best Lawyers, 2005 - 2019
- Texas Women Lawyers, Best Lawyers, 2014
- Texas Super Lawyer, tax, Thomson Reuters, 2006, 2008 - 2015
- Best of Business Attorneys & Corporate Counsel, corporate & tax, Austin Business Journal, 2006
- "Federal Tax Issues Related to Professional Courtesy and Cafeteria Discounts," American Bar Association Health Law Section Newsletter, August 2005
- "Output Facilities: Final Treasury Regulations," Texas State Bar Section of Taxation Newsletter, December 2002
- Co-author with Hank Still, "Entity Selection: A Survey of Issues Relevant to the Selection of the Form of Entity in Which to Do Business," April 1998
Joy has served as a panel member at seminars conducted by the National Association of Bond Lawyers on tax-exempt finance matters and has given speeches to professional organizations such as the Texas Association for Healthcare Financial Administration.
Memberships and activities
- American Bar Association
- State Bar of Texas
- Tax-Exempt Finance Committee, Member
- Former Court Procedures Committee, Officer
- National Association of Bond Lawyers
The IRS provides additional guidance on the type of remedial action that issuers may take to preserve the tax-advantaged status when there is an occurrence of “nonqualified uses” of bond proceeds..
May 03, 2018
We are writing to alert you to a serious threat to your continued ability to finance capital assets with tax-exempt bonds..
November 02, 2017