• Share
  • Email
  • Print

Virginia Leggett Stevenson

Partner
+1.704.331.7512
Fax +1.704.353.3212
Ms. Stevenson focuses her practice on mortgage and asset-backed securities, debt instruments and modifications, and securitization and business tax issues. She has represented underwriters, servicers, and trustees in all aspects of securitization transactions, including developing novel structures in agency REMICs.

Professional Background

Ms. Stevenson served as a law clerk to The Honorable Gerald B. Hanifan, New Jersey Superior Court from 1996-1997.

Professional/Civic Activities

  • American Bar Association, Chair, Basis and Adjustments to Basis Subcommittee; Sales, Exchanges, and Basis Committee; Taxation Section
  • American Bar Association, Taxation Section, John S. Nolan Fellow, 2004-2005
  • The Light Factory, Board of Directors, 2005-2011
  • Junior League of Charlotte
  • William & Mary Class of 1993 10th Reunion Gift Committee
  • William & Mary Class of 1993 15th Reunion Gift Committee
  • William & Mary Class of 1993 20th Reunion Gift Committee

Speaking Engagements

  • "FIRPTA Fundamentals," February 2016
  • “REMIC Terminations,” February 2015
  • "An Introduction to LIBOR, Its Recent Unpleasantness, and Its New Administrator," May 2014
  • “Interest, Unstated Interest, & Original Issue Discount: Issue-Spotting, Analysis, and Disclosure Issues,” May 2013
  • "REMIC Tax Rules," November 2011
  • "Commercial and Residential Loan Modifications," February 2008
  • "REMIC Loans: Can We Codify What it Means to Modify?" panelist at The American Bar Association Sections of Taxation and Real Property, Probate and Trust Law, October 2007
  • "Swap and Defease; Can it be Done with Ease?" panelist at The American Bar Association Tax Section Meeting, January 2007
  • "Section 199 Regulations," panelist at The American Bar Association Sections of Taxation and Real Property, Probate and Trust Law, 2006 Joint Fall CLE Meeting, October 2006
  • "Code Section 199 for Real Estate Transactions," presentation at Real Esate Conference, May 2006
  • "Advanced 199 for Real Estate," presentation to American Bar Association, Taxation Section, 2006
  • "New Proposed 199 Regulations: How They Affect the Structure of Real Estate Transactions" presentation to the American Bar Association, Joint Meeting of the Taxation and Real Property, Probate and Trust Law Sections, 2005
  • "Non-Debt Instrument Realization Events," American Bar Association, Taxation Section, 2005
  • "Young Lawyers Initiation to Section 1031 Like-Kind Exchanges," American Bar Association, Taxation Section, 2005
  • "The Tax Treatment of Acquired Contingent Liabilities," American Bar Association, Taxation Section, 2004
  • "New Developments in Depreciation," Outline for American Bar Association, Taxation Section, 2004
  • "Impact of the Jobs and Growth Tax Relief Reconciliation Act of 2003," presentation to the American Bar Association, Joint Meeting of the Taxation and Real Property, Probate and Trust Law Sections, 2003
  • "Section 121: the Road Not Taken and the Questions that Remain," American Bar Association, Taxation Section, 2003
  • "Tax and Estate Planning for Foreign Nationals," 2003
  • "Is Tax Structuring Still Possible?," American Bar Association, Taxation Section, 2003
  • Represented underwriter of securities in obtaining private letter ruling from the IRS allowing a grantor trust to issue floating and inverse-floating rate securities.
  • Represented underwriter in revival of Ginnie Mae REMICs with forward hybrid ARM collateral.
  • Represented underwriter of first Ginnie Mae REMIC with reverse-mortgage collateral (“HREMICs”).
  • Represented underwriters of Ginnie Mae HREMICs with respect to tax and structuring issues.
  • Represented underwriters of Ginnie Mae, Freddie Mac and Fannie Mae REMIC and grantor trust certificates.
  • Represented issuers and underwriters in single- and multi-family residential mortgage-backed securities programs.
  • Represented servicers, trustees and borrowers with respect to REMIC loan modification and tax issues.
  • Represented distressed debt fund with respect to tax issues.
  • Represented trustees in residential and commercial mortgage-backed securities.
  • Advised participants in REMIC terminations and clean-up calls.