Hunter J. Brownlee

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601 Bayshore Boulevard, Suite 700
Tampa, Florida 33606
Phone: (813) 253-2020 ext. 154
Fax: (813) 251-6711

Hunter is a Board Certified tax attorney who specializes in the areas of federal, state and local taxation. He advises and counsels clients in structuring taxable and non-taxable mergers, acquisitions, divestitures, spin-offs, split-ups and split-offs, and provides entity selection advice with respect to organizing corporations, partnerships, limited liability companies and other joint ventures. Hunter advises as to the advantages and disadvantages in making S corporation elections, and has substantial experience in drafting shareholder agreements, partnership agreements and operating agreements, particularly in drafting federal income tax specific provisions. He also has substantial experience in real and personal property loan workouts and modifications and loan purchase and sales. Hunter’s experience additionally includes:

  • Advises on issuance of equity interests in corporations, partnerships and limited liability companies to employees and independent contractors, and the income and employment tax consequences of issuing profits and capital interests;
  • At the end of the business cycle, assists with tax planning in dissolving and liquidating the entity, including determining gain recognized by the corporation, partnership or limited liability company and the effect on the shareholders, partners and members, and quantifying cancellation of indebtedness income, if applicable;
  • Has experience with forward, deferred and reverse like-kind exchanges, investor vs. dealer issues, and structuring real estate investment and development transactions;
  • Advises on tax ramification in organizing and operating tax-exempt entities and foundations, differences between public charities, private operating foundations and private nonoperating foundations, and the applicability of unrelated business taxable income; and
  • Advises on nexus issues for sales tax and income tax in Florida and other states, including the economic presence nexus theory and structuring strategies to minimize taxation by non-Florida states of Florida based businesses.

Hunter is married and has one son.

PRACTICE AREAS

  • Business Law
  • Tax Law

EDUCATION

  • University of Florida, Taxation LL.M. (1996)
  • Stetson University College of Law, J.D.(1995)
  • Vanderbilt University, B.A. (1992)

ADMISSIONS

  • The Florida Bar

COURT ADMISSIONS

  • U.S. Tax Court

DISTINCTIONS

  • THE BEST LAWYERS IN AMERICA, 2008-2021
  • BOARD CERTIFIED in Tax Law, The Florida Bar
  • SUPER LAWYERS in Tax Law, 2021
  • CHAMBERS USA, 2007 and 2008, Listed as an Up and Coming Tax Lawyer in Florida

PRESENTATIONS

  • “State and Local Tax Considerations When Buying or Selling a Business.” Speaker, The Florida Bar Tax Section CLE Seminar, October 2007

PUBLICATIONS

  • “Does Your Shareholder Compensation Include Profits Derived from Associates and Paralegals?” Author, Hillsborough County Bar Association Lawyer, February 2002
  • “Florida Income Tax Return Required for Grantor Tax.” Author, Tax Section Bulletin of the Florida Bar, March 2000
  • “Summary of Proposed Revisions to Subchapter S.” Co-Author, Tax Section Bulletin of the Florida Bar, 1999
  • “No Florida Documentary Stamp Tax Due Conversion of Partnership to Corporation.” Author, Tax Section Bulletin of the Florida Bar, 1997
  • “Tax Deductions for Leases of Luxury Boxes at the Sports Stadiums & Arenas.” Author, The Hillsborough County Bar Association Lawyer, November 1997
  • “Three-Day Seminar Held Insufficient to Establish Substantial Nexus to the State for Purposes of Imposing Sales Tax on Mail Order Items.” Author, Tax Section Bulletin of the Florida Bar, 1997
  • “Shareholders’ Agreement: A Contractual Alternative to Oppression as a Ground for Dissolution.” Author, 24 Stetson Law Review, 1994

PROFESSIONAL AFFILIATIONS

  • The Florida Bar: Member, Executive Council, Tax Section; Director- Long Range Planning, Former Chair, State Tax Division; Former Co-Chair of Education Division; Former Chair of New Tax Lawyers’ Committee
  • American Bar Association
  • Hillsborough County Bar Association

COMMUNITY INVOLVEMENT

  • Exchange Club of Tampa, Past President
  • Andrew’s Society of Tampa Bay, Past President
  • Palma Ceia Presbyterian Church, Past Elder
  • Eagle Scout
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