Mary F. Voce

Mary F. Voce

Shareholder

Mary F. Voce Chairs the Cross Border Tax Planning Practice and 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.

Concentrations

  • Tax planning for international transactions and investments
  • In-bound and out-bound cross border mergers, acquisitions, reorganizations and joint ventures
  • Aircraft finance and leasing
  • Tax aspects of project finance
  • Investment by foreign investors in U.S. real property
  • Capital markets offerings
  • Global Energy & Infrastructure
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Capabilities

Experience

  • Provided tax advice on investment in $425,000,000 of 3.79% Guaranteed Senior Secured Notes due June 25, 2027 issued by an affiliate of the Manchester United football team that is dual resident of the UK and US, requiring compliance with the withholding tax provisions and documentation requirements of both countries.
  • Provided international tax structuring advice to a taxable Panama finance company that is owned by several bi- and multilateral development organizations, in restructuring its U.S. based holdings in an approximately $100,000,000 portfolio of loans to Latin American borrowers.
  • Provided U.S. tax advice to a Canadian publicly traded corporation, with respect to the U.S. tax consequences to its U.S. shareholders of its acquisition of another Canadian publicly traded corporation. In this C$520 million transaction, shareholders of one company exchanged their shares and options for shares and options of another company, Questions arose regarding the treatment of the transaction as a tax free reorganization for U.S. tax purposes and the impact of the transaction on passive foreign investment company (“PFIC”) status.
  • Provided U.S. tax advice to an Argentinean airline in connection with the offering of U.S. dollar denominated redeemable notes in the aggregate principal amount of US$400,000,000.The notes were offered in the U.S. in reliance upon Rule 144A, with applications pending for listing on the Luxembourg Stock Exchange for trading in the Euro MTF Market and the Mercado de Valores de Buenos Aires S.A. (“MERVAL”) and in the Mercado Abierto Electrónico S.A. (“MAE”).
  • Represent U.S. company in the strength training space in connection with its expansion into multiple foreign countries, including development of an efficient tax structure, the establishment of subsidiaries/branches and coordination of foreign tax compliance requirements.
  • Advised Korean investment entity on structuring in-bound investment in multiple U.S. luxury hotels in New York, San Francisco, Boston, Washington D.C., Fairfax, Virginia and Miami having an aggregate value of over $600 million.
  • Advised on U.S. tax structuring for a U.S. owned company opening trade or business in Puerto Rico to take advantage of Puerto Rico tax incentives. Issues included U.S. corporate inversion rules, the source of income earned by the Puerto Rican corporation, the source of dividends paid by the corporation, the application of the controlled foreign corporation (“CFC”) and passive foreign investment company (“PFIC”) rules, and the taxation of gain from the sale of the stock of the Puerto Rican corporation.
  • Provided U.S. tax advice to multiple U.S. real estate developers and operators and foreign investors in structuring inbound investment by publicly traded, privately owned and government owned companies, pension plans and insurance companies located in the Middle East, China, Korea, Europe, Canada, Israel and Latin America in U.S. real estate development projects and the acquisition of operating properties such as office buildings, hotels, casinos and multi-family properties, including transactions involving treaty and non-treaty jurisdictions, indebtedness qualifying for the portfolio interest exemption, participating debt and Sharia financing.

  • Provided U.S. tax advice to Latin American Airline in connection with the issuance of notes to finance and the acquisition and leasing of five Boeing model aircraft to be owned through a U.S. owner trust.
  • Advice to U.S. organizers of new Caribbean airline on the U.S. tax consequences of operating flights to, from and within the U.S.

  • Extensive work advising U.S. and foreign entities on their FATCA reporting requirements and assistance with compliance

Recognition & Leadership

  • Listed, The Best Lawyers in America, Tax Law, 2007-2019
  • Shortlisted, Euromoney Legal Media Group’s Americas Women in Business Law Awards, "Best in Tax," 2016 and 2017
  • Winner, Euromoney Legal Media Group’s Americas Women in Business Law Awards, "Best in Tax," 2014-2015
  • Listed, The Legal 500 United States, 2007, 2009, 2014 -2018
    • International Tax, 2007, 2009, 2014 -2018
    • U.S Taxes - Non-Contentious, 2018
  • Listed, Super Lawyers magazine, New York Metro Super Lawyers, 2006-2018
    • Listed, "Top 50 Female Attorneys in the New York Metropolitan Area," 2009
  • Listed, Euromoney's Expert Guides: Women in Business Law, "Guide to the World's Leading Women in Business Law," 2014 and 2017
  • 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, 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

AV®, AV Preeminent®, Martindale-Hubbell DistinguishedSM and Martindale-Hubbell NotableSM are certification marks used under license in accordance with the Martindale-Hubbell® certification procedures, standards and policies.

  • Board Member, International Tax Institute, Board of Directors
  • 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

Credentials

Education
  • LL.M., Tax, New York University School of Law, 1975
  • LL.B., University of Virginia School of Law, 1969
  • B.A., University of Michigan, 1966
Admissions
  • New York