BLANDIN J. WRIGHT

Estate Tax Attorney / CPA: LL.M (Tax NYU); M.S. Tax (w/ Honors) J.D; CGMA

Bar: Admitted: Florida; Pennsylvania; D.C.; Virginia; New York; U.S. Supreme Court; U.S. Tax Court.

Entity Formation LLC’s, CTBE’s, Trusts

Corporate, Partnership & Individual Tax

Tax Planning, Compliance, Controversies

Estate Tax & Gift Tax, Deferred Comp.

Real Estate Transactions & Exchanges

Consolidated Returns Issues

Tax Accounting & Provisions

U.S. & Foreign Asset Protection

EXPERIENCE

BJW P.A., Boca Raton, FL. June 1, 2014 - Present

Sole Practitioner

Practice centers on: Tax, Corporate, Estate & Gift Tax, Wills & Estates on behalf of high net worth individuals, families, and corporations (one has $1.5 billion net worth). To a lesser extent, practice includes: Asset Protection (set up, organize, and qualify U.S. and foreign entities; also sets up and qualifies IRC sec. 501(c)(3) Charitable Foundations); handle Forms 706 & 709 Estate & Gift Tax filings and related IRS Audits. Advise individuals, public and privately held companies in areas such as Transaction Structuring, Check the Box Principles, and general corporate, partnership, LLC, Trust and individual tax matters. Deal with Federal & State Tax Audits and Appeals, construction and filing of current and prior years’ tax returns for individuals, partnerships and corporations. Prepares FINCEN Form 114 and other Foreign Bank Account Reports (FBAR). Firm is continuation of my prior Estate Tax Planning/Compliance and related practice in Florida (1995 – 2010) and Charlottesville, VA (1982 - 1989 below).

Shell Oil Company, Houston, TX. June 1, 2010 – May 31, 2014

Senior Tax Counsel

Involved with Federal, State and Foreign Tax Matters. Also handled corporate mergers, acquisitions, divestitures, spin-offs, including Affiliated Groups and Deconsolidations. Ensured compliance with 80/20 Company Transition rules, Anti-Boycott Reports, Check the Box Planning. As a CPA & CGMA, worked with SFAS 109, FIN 48, and other tax accounting areas. Devised Reconsolidation Plan for U.S. Tax Groups which utilized otherwise expiring FTC Carryovers, which freed up blocked cash. Involved with Master Limited Partnership planning for new subsidiaries. Reviewed proposed tax law changes that could affect the Company, met with House Ways & Means Committee, Senate Finance Staff, and the Joint Committee on Taxation to discuss the Camp, Enzi and Bachus Tax proposals. Advised on State & Local tax matters such as Apportionment Factors and related issues, including obtaining state grants for construction projects.

QPWB / RRA / Becker & Poliakoff / Maritime Capital Group, Miami, FL. Aug. 1995 – May 31, 2010

Head of Tax Department& Transactional Groups / Chief Tax Officer

Practice centered on: Tax, Estate Planning, Wills, Deferred Compensation, Probate, & Corporate on behalf of closely–held and public companies, as well as high and middle-market net worth individuals. Worked in Corporate, Partnership, LLC, individual income tax, Alternative Minimum Tax and estate tax & succession planning, deferred compensation and retirement and 401(K) plans. This includes comprehensive tax planning/consulting work that produces detailed tax plans and illustrations. The tax issues have included NOL carryforwards, Subchapters C & K topics, sec. 368 Reorgs, Tax Treaty interpretation, and other areas of global tax minimization. Restructured foreign operations into Qualified Treaty entities to qualify dividends for the U.S. 15% (now 20%) QFD tax rates, instead of the ordinary income rates. As an expert in Subpart F, restructured certain CFC’s companies to avoid shareholder taxation of undistributed corporate earnings while operating free of U.S. and other corporate income tax pursuant to IRC sec 883. Worked with Inbound

and Outbound transfers, section 367, Treaty Interpretation, Foreign Tax Credits (direct, indirect, and “in lieu” of credits), and basket / limitation issues. Involved in tax controversy work, filing protests, appeals, complaints & answers with the IRS, Tax and Federal District Courts. Handled tax and related legal, accounting (FAS 109 Deferred Tax Assets & Liabilities) and financial issues. Completed a debt to equity restructuring / takeover of a public company. Advised and represented Hedge Funds and Ecommerce companies. Involved in formation and structure of certain hotel and condominium partnerships and corporations, including the implementation of Capital Gains Bailout strategy for pre-development real estate owners, and Capital Gains Holdbacks for developers. Closed Section 1031 Like Kind Exchanges, handled REIT and other issues. Revised and set up employee benefit, tax and 401(k) plans. Supervised and mentored staff, heavily involved with marketing, putting on seminars which augmented and increased the Firms’ practice and client mix.

Mobil Oil Corp, New York, NY & Fairfax, VA Jan. 1990 – Aug. 1995

Tax Counsel

Worked on tax issues involving corporations, partnership and joint ventures (electing out of Subchapter K), tax disputes, foreign tax credits (direct, indirect), interest allocations, transfer pricing, financings, acquisitions, sales, section 1031 exchanges, farm outs & ins. Dealt with IRS IDR's, Alternative Minimum Tax, & other audit and FAS 109 Deferred tax issues. Rebutted IRS arguments that billions of dollars of taxes paid under Production Sharing Contracts did not qualify for the U.S. FTC’s. Received award from the Board of Directors for structuring 1st Japanese entity majority owned by a U.S. company to obtain Japanese Government funding for investment outside Japan, via a corporation minority owned by Russian, Vietnamese, and Japanese entities. (All dividends were fully covered by FTC’s). Involved with investment and transmission projects set up as partnerships and joint ventures with other corporations (e.g., upstream & downstream entities).

Richmond & Fishburne / BJW PC / J. Lauritzen A/S, Charlottesville, VA July 1982 – Dec. 1989

Tax Partner/ V.P. Tax & CFO

Practice centered on: Tax, Estate Planning, Trusts, Employee Benefit & 401(k) Plans on behalf of corporations, partnerships and high net worth individuals. Involved in wide range of commercial issues, real estate, formation of partnerships and corporations, litigation, and M & A work. Represented diverse clientele (e.g., Mohammed Ali plus additional multi-millionaires) in commercial, tax, real estate, coal, oil & gas, trading activities and other matters. Involved with disputes with the IRS, and handled federal and state tax return filings and other compliance issues on behalf of corporations and partnerships I had formed: over a hundred company returns and a thousand individual limited partners and shareholders tax returns pertaining to entities that I had formed on behalf of clients. As V.P. Tax & Finance for J. Lauritzen A/S, handled all federal, state and local tax, and related financial issues for this publicly corporation that was active in all areas of shipping, energy, and offshore drilling. This included planning and compliance. Set up one of the first 401(k) Plans. Involved in corporate financing, leasing, contract negotiation and related tax planning. Won a $20 million breach of contract case vs. Occidental Petroleum, represented by Baker & Botts at the Arbitration and Federal District Court level, and then Louis Nizer on appeal. Heavily involved in marketing and often lauded by partners for marketing successes on behalf of firm. Supervisory functions.

Oiltools International Limited, London, England Aug. 1979 – July 1982

Vice President Finance& General Counsel

Chief Tax & Finance officer for a Division owned by the NYSE Co. ENSERCH Corp. (later acquired by TXU), that had acquired former employer Intairdril Limited. Responsible for federal, state & local tax compliance, filings, and planning. Reviewed contracts, M&A transactions, tax planning (section 482 intercorporate pricing, subpart F, Chapter C, sec. 368 reorganizations, and general corporate issues. Obtained Tax Rulings from European and Asian Governments that allowed world-wide trading company to operate essentially tax

free. Met with House Ways and Means Committee Chairman & Staff, assisted in increasing the IRC sec. 911 foreign earned income exclusion, and introduced the excess foreign housing deduction. Set up and monitored Tax Protection Programs, and other employee benefit programs. Set up Liechtenstein Foundations trusteed by Credit Suisse. Heavily involved in planning and compliance with the Treasury & Commerce Dept. anti-boycott laws, and Foreign Corrupt Practices Act. Utilized Mere Expediting Payment exception to regain assets expropriated in Iran. Managed tax audits, administrative and judicial appeals.

Allied Chemical Corporation, Houston, TX Mar. 1978 – Aug. 1979

Tax Attorney

Handled full range of tax issues, domestic and international, including farm-outs and farm-ins for its Union Texas Petroleum Division. Wrote the Oil & Gas Tax Law for Bahrain (and amendments to other countries laws and Production Sharing Contracts and Concessions) so that "taxes" paid by a U.S. company would qualify as creditable foreign income taxes (IRC Secs. 901 & 903), pursuant to U.S. Treas. Regs., which were revised during this process. Modified foreign countries related Boycott laws to not violate IRC and U.S. Commerce Dept. regulations. Reviewed contracts, set up companies, joint ventures, & partnerships, and advised on the tax effects. Left when recruited by former employer to return to London.

Intairdril Limited, London, England & Houston, TX Nov. 1976 – Mar. 1978

Tax Manager, then Tax Director

Responsible for all tax issues, federal and state, of this U.S. privately held multinational oil services group of companies that also leased and sold equipment (based in London, and then Houston). Handled tax and audit issues re federal, state, local, and other returns. Monitored all anti-Boycott issues resulting from the

U.S. 1976 Tax Reform Act & U.S. 1977 Commerce Department Act. Reviewed and negotiated contracts and leases, and did M & A transactions. Also handled corporate secretarial and related corporate governance and insurance work. Established Company Tax Protection Plan, and handled all Compliance / Return issues, including state matters when the Corporate H.Q. relocated to the USA. Left when the company was purchased by Enserch Corporation.

Internal Revenue Service, Trenton, NJ & Washington, DC Aug. 1973 – Nov. 1976

Estate & Gift Tax Attorney

Worked initially in a Regional Office for one year, handled a wide range of Estate & Gift tax audits, and dealt with law firms, CPA firms, and other Representatives of taxpayers. Valued closely held businesses utilizing Book & Adjusted Book Value, Comparable Sales, Price/ Earnings ratios, Dividend Capitalization on, and other methods. Was promoted to the National Office in Wash. D.C., and worked in the Office of International Operations for a year, where I was assigned a large case load. Then was promoted to the Technical Division, where I wrote Estate & Gift Tax Letter Rulings, Technical Advice Memoranda, et al. Reviewed complicated Wills and Trusts, decided what marital, charitable and other provisions did not qualify for tax deductions. Received a special award for work I did in utilizing a computer to solve complicated estate tax interrelated computation issues submitted to the National Office by the IRS Regional Officers and taxpayers. Left to work in London for U.S. controlled group of corporations.

EDUCATION

American University Kogod Graduate Business School, Washington, DC

Master of Science in Taxation, with honors, June 1992.

Earned degree while full time Tax Counsel for Mobil Oil. Beta Gamma Sigma Honorary Business Fraternity.

New York University Graduate Law School, New York, NY

Master of Laws in Taxation, January 1974, from the Nation’s #1 Tax Program.

Pennsylvania State University Dickinson School of Law, Carlisle, PA

Juris Doctorate, June, 1972.

Honors: Selected for Appellate Moot Court Board, ranking 1st in the mandatory competition. Received American Jurisprudence Award for the highest grade in State & Local Government Law.

University of Michigan, Ann Arbor, MI

Bachelor of Arts, May, 1969. Major: Political Science; Minor; Economics. Honors: Selected for the Advanced Unified Science Program.

National Merit Scholarship Finalist.

CPA LICENSES

Certified Public Accountant:

Admitted: Texas, 1978; Virginia, 1983; AICPA; Chartered Global Management Accountant, 2012

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