Marshall Olney is an associate in Buchalter’s Los Angeles office in the firm’s aviation finance, international business & trade, tax, and corporate practice areas. He advises clients on domestic and cross-border transactions involving aircraft acquisition, financing, leasing, and export, and provides guidance on international trade compliance and finance. Marshall also supports clients in navigating the international and domestic tax and transactional aspects of mergers and acquisitions, venture capital, and inbound and outbound investments and business structuring. His international practice focuses on matters involving China, Japan, and Southeast Asia.
Marshall is admitted to practice law in California (Bar No. 343717) and is also admitted as a solicitor in the United Kingdom (No. 7811851). He has a background in both civil and military aviation and holds an FAA Airline Transport Pilot Certificate (No. 2783017). He is also licensed in California as a Property and Casualty Agent-Broker (No. 4522898) and has applied for a U.S. Customs Broker License after passing the August CBP exam.
Marshall’s aviation practice is complemented by his experience as both a civil and military aviator. His aviation-related matters include:
- Structuring the transactional and tax aspects of aircraft acquisitions, financing, securitizations, leasing arrangements, joint ownership structures, and charter management agreements.
- Advising on corporate aircraft purchase and sale transactions.
- Advising aviation clients on business structuring for aircraft ownership, charter operations, maintenance businesses, and aircraft manufacturing ventures.
- Advising clients on aircraft export transactions.
- Advising clients on California sales and use tax issues related to aircraft.
- Advising international aircraft operators on the tax aspects of their operations.
- Assisting clients with the sale of aviation businesses, including aircraft operators, aviation maintenance businesses, and aircraft parts manufacturers.
- Assisting California clients with filing FAA mechanics’ liens.
Marshall advises clients on a range of international trade matters, including:
- IEEPA tariff refunds.
- Customs and import matters, including classification, valuation, drawback, cargo seizure, CBP administrative protests, country-of-origin determinations, and related transfer pricing and tax issues.
- AML/KYC and TBML compliance issues.
- Structuring and drafting trade finance agreements, including letters of intent (LOI) and standby letters of credit (SBLC).
Marshall’s tax and transactional practice focus on M&A and venture capital transactions, as well as international business tax including:
- Advising on domestic and cross-border tax and transactional aspects of asset and equity acquisitions during the LOI phase to minimize adverse tax consequences.
- Negotiating, drafting, and implementing asset and equity purchase transactions, including F reorganizations.
- Advising emerging and developing companies on business structuring and financing strategies.
- Advising on inbound and outbound investment transactions.
- International tax structuring involving NCTI, Subpart F, PFIC, CFC, BEAT, transfers to foreign entities, FBAR (FinCEN Form 114), sourcing of income and reporting (Form 5471), tax treaty implications, foreign currency and debt taxation, and transfer pricing.
- Drafting partnership and LLC operating agreements for international joint ventures.