B. Cary Tolley, III advises clients on domestic and cross-border business federal income tax matters, international tax planning, real estate and energy property tax credits, and leasing and project finance tax advice.
Cary’s practice experience includes all federal income tax matters relating to inbound and outbound international tax planning and both domestic and cross-border leasing and project finance tax advice.
He has more than 20 years of large, complex cross-border finance transaction experience. He has extensive practice experience with partnership tax matters and both real estate-related and energy property tax credits as well.
Cary served as managing partner of the firm’s New York office from 1990 to 2006 and as head of the firm’s tax and ERISA team from 1984 to 1999. He is a former Lieutenant, United States Navy Reserve, JAG Corp.
- Provided tax planning for several project finance transactions involving multiple jurisdictions.
- Provided tax planning for non-US businesses of US companies, offshore funds, domestic and international lease financings, service contract financings, public offerings and private placements of debt and equity securities.
- Provides practice advise for US branch profits taxation, US withholding taxes, Subpart F advice, PFIC analysis and US bilateral tax treaty planning.
- Defense of taxpayer on highly structured or complex transactions and offshore account disclosure matters.
- Advising individuals and families regarding US tax residency and/or dual citizenship tax matters.
- Negotiating/structuring partnership agreements involving real estate and energy property assets.
- LLM, Taxation, University of Florida, 1978
- JD, Washington and Lee University School of Law, summa cum laude, 1975
- BA, Political Science, Yale University, 1972
- New York
- Member, Tax Section, American Bar Association
- Fellow, American College of Tax Counsel
- Former Trustee, New Covenant Trust Company, a subsidiary of the Presbyterian Church USA Foundation, 2005-2012
- Former Trustee, Presbyterian Church USA Foundation, and Presbyterian Investment Loan Program, 1994-2003
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