Cary 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.

Bar Admissions

Education
LLM, Taxation, University of Florida, 1978

JD, Washington and Lee University School of Law, summa cum laude, 1975

BA, Political Science, Yale University, 1972

• US and foreign tax planning for several multijurisdiction project finance transactions funded from multiple jurisdiction equity sources.
• Tax planning for non-US businesses of US companies, offshore funds, 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 emphasizes US branch profits taxation, US withholding taxes, Subpart F advice, PFIC analysis and US bilateral tax treaty planning. Practice includes federal tax controversy work, with emphasis on taxpayer defense of highly structured or complex transactions and offshore account disclosure matters, and 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.

• 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

• Named a Lawyer of the Year for Equipment Finance Law (2013); selected as a Best Lawyer for Equipment Finance Law, New York, Best Lawyers in America, 2012-2017. A description of the selection methodology can be found on Best Lawyers’ webpage.

• Equipment Leasing: Theory and Practical Guidance, Equipment Leasing, Vol. 2, Ch. 24, Lexis/Nexis, Chapter Contributing Author, 2015 update