Marshall Olney
Practice Expertise
- Tax, Benefits and Estate Planning
- Greater China Practice
Areas of Practice
- Tax, Benefits and Estate Planning
- Greater China Practice
Profile
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.
Bar Admissions
California
Supreme Court of the United States
U.S. Court of Appeals for the Ninth Circuit
U.S. Court of International Trade (CIT)
U.S. Tax Court
England and Whales Solicitor
Education
Loyola Marymount University, LL.M. in Tax Law
Texas A&M University, LL.M., International Tax Law
Shanghai Jiao Tong University Koguan Law School, LL.M., Chinese Business Law
Santa Clara University School of Law, J.D., High Tech Law Certificate and Corporate Specialization
Santa Clara Leavy School of Business, MBA, Finance Concentration
Embry-Riddle Aeronautical University, M.S., Aeronautical Science
Southern Illinois University, Carbondale, B.S., Aviation Management
Areas of Practice
- Tax, Benefits and Estate Planning
- Greater China Practice
Professional Career
Articles
Agustín Ceballos and Marshall Olney Speaking at LA Tax Night
Tax Relief and Recovery: Key Considerations for Los Angeles Residents Affected by Recent Wildfires
Key Tax Changes in Public Law 119-21: What Individuals and Businesses Need to Know
Stuart Simon and Marshall Olney, Speakers at 2025 GLAALA Webinar
FinCEN Announces "Data-Driven Border Operation to Address Potential Money Laundering"
FinCEN announces 'data-driven border operation to address potential money laundering' - Westlaw Today
Learning Resources v. Trump:
After Learning Resources v. Trump: Strategic Paths to Recovering Unliquidated IEEPA Tariffs Through Post-Summary Corrections
One Small Step for Importers: Federal Circuit Clears the Way for IEEPA Tariff Refund Litigation to Resume
CIT Orders CBP to Remove IEEPA Tariffs from Unliquidated Entries - Pressure Builds on CBP to Roll Out a Refund Procedure.
CIT Hits Pause on Immediate IEEPA Tariff Relief While CBP Builds Refund Process
Preserve Your Rights or Pay the Price: CIT Urges Importers to File Protests to Protect Liquidated IEEPA Refund Claims Still Eligible for Protest.
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