Stephen J. Watson

Partner Norton Rose Fulbright US LLP
Stephen J. Watson

Stephen J. Watson

Biography

Steve Watson practices in the areas of tax, energy and public finance. He serves as tax counsel to issuers of tax-exempt bonds and owners of energy projects eligible for federal tax credits. He has extensive experience representing state and local governments, tax-exempt organizations, public power agencies and energy companies in a wide range of transactions, including financings for governmental and privately owned infrastructure, prepayments for natural gas and electricity, and healthcare, housing, education, utility, transportation and energy facilities.

Before he joined the firm in 2006, Steve served as Associate Tax Legislative Counsel in the US Treasury Department's Office of Tax Policy. At Treasury, he was responsible for policy matters and published guidance relating to municipal finance, including arbitrage and private use rules, refundings, financial products, clean renewable energy bonds, and private activity bonds for solid waste recycling facilities. He was a principal author of regulations that facilitate participation by public power agencies in regional transmission organizations, regulations that authorize tax-exempt financing of energy prepayments, rules that govern tax-exempt debt issuance in healthcare acquisitions, regulations on the new markets tax credit, and legislation that authorizes tax-exempt private activity bonds for P3 transportation projects.

Professional experience

Representative experience

Representative experience

Representation of large US municipality in the financing of its capital program consisting of more than 20,000 projects at any one time

Tax counsel to municipal utilities and other state and local governments regarding direct-pay investment tax credits for solar, wind, and battery energy storage facilities

Representation of statewide public power agency in the financing of its electric system assets including nuclear, natural gas, coal, hydroelectric and wind generation facilities, and transmission and distribution facilities

Advising utilities and energy companies on tax-exempt private activity bonds for a broad range of facilities including dairy renewable natural gas, renewable hydrogen, renewable diesel fuel and sustainable aviation fuel

Representation of tax-exempt colleges, universities and secondary schools in the issuance of qualified 501(c)(3) bonds for educational facilities

Tax counsel to joint action agency in the issuance of tax-exempt debt to finance electric generation and transmission facilities and prepaid natural gas and electricity supplies for the benefit of municipal electric utilities

Representation of issuers in matters before the Internal Revenue Service including requests for private letter rulings and voluntary closing agreements, and examinations and appeals

Representation of municipal issuer in its program for financing prepaid natural gas supplies for municipal gas and electric utilities throughout the country

Representation of medical center in the issuance of qualified 501(c)(3) bonds to acquire assets from an affiliated university

Rankings and recognitions

Rankings and recognitions

Lawdragon 500 Leading Global Tax Lawyers

Education

Education

LLM, Taxation, Georgetown University Law Center, 1992
JD, Georgetown University Law Center, 1989
BA, Williams College, 1985

Admissions

Admissions

  • California State Bar
  • District of Columbia Bar
  • Minnesota State Bar
  • New York State Bar

Publications

Publications

  • "IRS notice expands authority of Texas Permanent School Fund to guarantee bonds of school districts and charter schools," May 2023
  • "Inflation Reduction Act Provides Major Tax Incentives for Public Power," Legal Update, October 11, 2022
  • "Private Activity Bonds for Carbon Capture," Project Finance Newswire, June 2022
  • Contributing author, "What US Municipal Securities Issuers Should Know About LIBOR Transition," Legal Update, November 2020
  • Contributing author, "New remedial action guidance for tax-advantaged bonds," Legal Update, May 2018
  • "IRS Issue Price Regulations Impose New Restrictions on the Offering and Sale of Tax-Exempt Bonds," Legal Update, April 2017
  • "Direct Payment Option Now Available for Issuers of Qualified Tax Credit Bonds for Schools and Energy Projects," Legal Update, March 25, 2010
  • Co-author, "Navigating the Stimulus Legislation's New Municipal Bond Provisions," Legal Update, April 13, 2009
  • "New Tax-Exempt Financing for Privately Owned or Used Facilities in Areas of Texas and Louisiana Affected by Hurricane Ike," Legal Update, December 15, 2008
  • "IRS Questionnaire on Post-Issuance Compliance for Governmental Tax-Exempt Bonds," Legal Update, August 19, 2008
  • "Important Developments in Tax-Exempt Financing for 2008," American Bar Association
  • "Important Developments in Tax-Exempt Financing for 2007," American Bar Association
  • "IRS Questionnaire on Post-Issuance Compliance for 501(c)(3) Tax-Exempt Bonds," Legal Update, August 22, 2007
  • "New IRS Record Retention Initiative for Tax-Exempt Bonds," Legal Update, May 30, 2007
  • "US Transportation Department Accepting Applications for $15 Billion of Private Activity Bond Authority," Legal Update, March 2006

Speaking engagements

Speaking engagements

  • SCPPA Webinar, "Inflation Reduction Act Workshop," October 25, 2022
  • Client Presentation, "Acquisition vs. Refunding Tax Treatment," San Francisco, California, November 1, 2018
  • Client Presentation, "The Final Issue Price Regulations," New York, New York, May 25, 2017
  • Fulbright Webinar, "Navigating the Stimulus Legislation's New Municipal Bond Provisions," May 19, 2009
  • Fulbright Webinar, "Preventing Post-Issuance Bond Blues in Texas," January 30, 2008
  • Bond Buyer California Public Finance Conference, "Clean Renewable Energy Bonds," San Diego, California, September 2007
  • American Public Power Association Winter Meeting, "Clean Renewable Energy Bonds," Arlington, Virginia, February 9, 2006
  • Bond Buyer Texas Public Finance Conference, "Transportation Private Activity Bonds," Austin, Texas, January 2006
  • Frequent panelist at meetings of the American Bar Association Tax Section and the National Association of Bond Lawyers

Memberships and activities

Memberships and activities

  • American Bar Association
  • National Association of Bond Lawyers

Insights and news