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Partner
Tax & ERISA Practice
Miami
(305) 810-2533 Phone
(305) 810-2460 Fax
New York
(212) 309-1180 Phone
(212) 309-1100 Fax
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| Practices |
Airline
Energy
Energy and
Infrastructure
International Estate
Planning
Leasing
Structured Financing
Taxation: Federal,
State, Local &
Cross-Border
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Practice focuses on all federal income tax matters relating to inbound and outbound international tax planning and renewable energy tax structuring advice. Those tax matters relate, in particular, to offshore tax planning for non-US businesses of US companies, domestic and international project finance and lease financings, service contract financings, public offerings and private placements of debt and equity securities, including mortgage servicer advance receivables financings, and a variety of US inbound international business transactions. Practice has emphasized advice regarding US branch profits taxation, Subpart F and FTC planning advice, PFIC analysis and US bilateral tax treaty planning. Practice also includes federal tax controversy work with emphasis on taxpayer defense of highly structured or complex transactions and offshore account disclosure matters.
Relevant Experience 
- Over 18 years of large, complex cross border finance transaction experience.
- U.S. and foreign tax planning for several multi-jurisdiction project finance transactions funded from multiple jurisdiction equity sources.
- International tax planning for off shore equity funds.
- Tax & Erisa team head from 1984 through 1999.
- New York office managing partner from 1990 to 2006.
Background
- Lieutenant, USNR, JAG Corp., 1975–78
Membership
- Member, Virginia State Bar
- Member, The Florida Bar
- Member, New York State Bar
- Past Chairman, American Bar Association, Tax Section, Committee on Capital Recovery and Leasing
- Former Trustee, Presbyterian Church USA Foundation, and Presbyterian Investment Loan Program
- Current Trustee, New Covenant Trust Company, a subsidiary of the Presbyterian Church USA Foundation
Education - LL.M., University of Florida, Taxation, 1978
- J.D., Washington and Lee University School of Law, summa cum laude, 1975
- B.A., Yale University, Political Science, 1972
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B. Tolley, III
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