Mary Voce concentrates her practice on corporate and international tax. She handles both in-bound and out-bound corporate and international tax planning for U.S. and foreign corporations, U.S. federal taxation of partnerships, limited liability companies, funds and joint ventures. She also handles U.S. federal tax aspects of cross-border corporate mergers, acquisitions and reorganizations, taxation of real estate investments, securities offerings by U.S. and foreign corporations, international projects, equipment leasing and financing.
Areas of Concentration
· Tax planning for international transactions and investments
· Corporate mergers, acquisitions, reorganizations and joint ventures
· Aircraft finance and leasing
· Project finance
· Transfer pricing
· Foreign real property investments by REITs
· Capital markets offerings
Professional & Community Involvement
· Board of Directors, International Tax Institute
· Member, The Tax Club
· Member, Association of the Bar of the City of New York
· Member, New York State Bar Association
· Member, American Bar Association
Awards & Recognition
· Listed, The Best Lawyers in America, Tax Law, 2007-2014
· Listed, Super Lawyers magazine, New York Super Lawyers, 2006-2013
- "Top 50 Female Attorneys in the New York Metropolitan Area," 2009
· Listed, Euromoney Institutional Investor's Expert Guides, "Guide to the World's Leading Women in Business Law," 2012
· Listed, AVENUE magazine, "Legal Elite," Real Estate, April 2011
· Listed, The Legal 500 United States, International Tax, 2007, 2009
· Listed, Guide to the World's Leading Tax Advisors in association with International Tax Review, "Leading Practitioner" (selected by in-house counsel and peers), December 2004
· Rated, AV Preeminent® 5.0 out of 5
· Structured numerous investments by foreign investors in U.S. real property, including transactions treaty and non-treaty jurisdictions, indebtedness qualifying for the portfolio interest exemption and participating debt.
· Provided U.S. tax advice to a number of U.S. companies doing business in China, including addressing Subpart F, inversion and transfer pricing issues.
· Provided U.S. tax advice on the acquisition, ownership and financing of life settlement portfolios.
· Developed tax efficient structure for development and ownership of biofuels project in Latin American.
· Coordinated the cross-border restructuring of multiple privately owned European corporate groups.
· Provided tax advice relating to clients' claims in Lehman bankruptcy.
· Advised on the availability of bad debt and worthless security losses resulting from the failure of foreign subsidiaries of U.S. corporations.
· Provided tax advice on the business combination of TTM Technologies, Inc., North America's largest printed circuit board (PCB) manufacturer, with Meadville Holdings Limited's PCB business, creating one of the largest PCB manufacturers in the world.
· Advised on a number of acquisitions by Canadian companies of U.S. assets and entities and vice versa.
· Provided tax advice in the acquisition by Perry Ellis International, Inc. of substantially all of the domestic operating assets of Tropical Sportswear Int'l Corporation (Nasdaq:TSIC) and the outstanding capital stock of Tropical Sportswear's U.K. subsidiary for an aggregate of $88.5 million in cash.
· Assisted in structuring the foreclosure by a syndicate of major U.S. insurance companies of the approximately $340 million Attala generating facility in Attala, Mississippi.
· Provided tax advice to U.S. creditors in connection with the bankruptcy of Aerovias Nacionales de Colombia S.A.Avianca ("Avianca S.A."), the Colombian airline.
· Assisted Citco Group in structuring a joint venture between Hamilton Court, a firm that invests in private equity funds on behalf of institutions, and Richcourt Holding, Inc., a BVI company that invests in private equity on behalf of individuals and pension funds.
· Has provided international tax advice in connection with the acquisition by U.S. REITs of real property in Canada, Mexico and the U.K.
· Has provided tax advice to developers of electrical power facilities in Latin America to structure holdings that will facilitate the admission of new investors and optimize the tax consequences to the parties.
Publications & Presentations
Articles, Lectures & Publications
· Co-author, "The Stop Tax Haven Abuse Act: Indications of Future Changes In International Tax Landscape." Practical U.S./International Tax Strategies, Vol. 13, No. 4, February 28, 2009
· Co-author, "Foreign Investors and Safe Tax: Always File Prophylactically," Banker and Tradesman, February 27, 2006
· Author, "Foreign Base Company Sales Income, A Primer and An Update," The Tax Lawyer, Vol. 53, No. 2, Winter 2000
· Author, "Basis of Foreign Property That Becomes Subject to U.S. Taxation," The Tax Lawyer, Vol. 49, No. 2, Winter 1996
· Co-author, "How Substance vs. Form Doctrine Applies to Cross-Border Leases," Leader's Equipment Leasing Newsletter, 1994
· Panelist, "Immigration and Tax Law: What's the Connection? U.S. Tax and Asset Reporting" webinar for the ABA Section of Litigation, Immigration Litigation Committee, November, 2011
· Lecturer, "Update on U.S. International Tax Developments & Investment in U.S. Real Property by Foreign Persons," The Association of the Bar of the City of New York, International Legal Training, April, 2010
· Lecturer, "A Discussion of tax issues arising in the structuring of inbound and outbound international corporate transactions," The Association of the Bar of the City of New York, International Legal Training, April, 2008
· Lecturer, "International Tax: A Discussion of Tax Issues Arising in the Structuring of Inbound and Outbound International Corporate Transactions," The Association of the Bar of the City of New York, International Legal Training, June 5, 2007
· Speaker, "2007 International Update: U.S.-Mexico Cross Border Tax Issues and Treaty Implications," Presented at Procopio International Tax Institute, February 2007
· Lecturer, "Select Issues Relating to Taxation of International Transactions," Association of the City of New York for International Legal Training: Strategic Directions for International Practice, March 21, 2006
· Lecturer, "Select Issues Relating to Taxation of International Transactions," Association of the City of New York for International Legal Training: Strategic Directions for International Practice, December 5, 2002