Enrique Hernandez-Pulido

Mr. Hernández-Pulido is a licensed attorney in Mexico and in California. His practice includes representing clients in international tax planning and related international matters, particularly Mexican and U.S.-Mexican legal matters. Mr. Hernández-Pulido represents clients in the development of business transactions, worldwide investment and financing structures, planning for worldwide income and estate and inheritance taxes.

Mr. Hernández-Pulido worked for several years in the Mexican government in the areas of tax, finance and administration, acting as Subprocurador Fiscal de la Federación (Under Fiscal Federal General Attorney) in charge of consultation and legislative issues, Director General Jurídico (Legal General Director) of IPAB (Mexico's Bank Deposit Insurance Federal Authority) and Director Jurídico (General Counsel) of FIDELIQ. Before his public career, Mr. Hernández-Pulido was an associate attorney for the law firm of Bryan, González Vargas y González Baz in Mexico City.

Mr. Hernández-Pulido has published articles on tax law and policy and has directed several tax related professional thesis. Before coming to San Diego, he was on the faculty at ITAM (Instituto Tecnológcio Autónomo de México) in Mexico City teaching advanced courses in tax law in its School of Law.

Representative Matters

• Representation of multi-national families (with a focus on Mexico) in developing worldwide income, estate and inheritance tax, international wealth preservation structures and pre-immigration international tax planning
• Structuring of complex transactions involving the merger, sale, and liquidation of Mexican and U.S. private and governmental entities and their corporate assets located in the U.S., Mexico and other jurisdictions
• Representation of Mexican manufacturing and service companies with respect to their U.S. matters, subsidiaries and operations
• Design, structure and implementation of outbound and cross-border tax plans for U.S. corporate and individual clients investing in Mexico
• Represents clients in structuring new business entities such as limited liability companies and corporations
• Represents clients in structuring international joint ventures and international reorganizations
• Assists U.S. clients in obtaining and coordinating competent and specialized Mexican legal counsel for different types of projects, matters or litigation
• Assists in structuring complex inbound tax plans for foreign individual clients
• Assists in structuring complex estate plans for foreign individual clients with economic U.S. interests and beneficiaries
• Assists in the representation of Mexican manufacturing and services companies with U.S. companies
• Assists in structuring new business entities such as limited liability companies and corporations
• Assists in structuring international joint ventures and international reorganizations
• Assists in the representation of multi-national families (with a focus on Mexico) in developing worldwide income, estate and inheritance tax and international wealth preservation structures

 Enrique Hernández-Pulido received his Mexican law degree (Licenciatura en Derecho) from Universidad Iberoamericana, where he graduated in 1992. Mr. Hernández-Pulido obtained a joint L.L.M./ITP degree in international taxation and tax policy from Harvard Law School in 1995, earning a special certificate of merit for excellence in research and writing for his Master's thesis titled "Alternatives for Taxing Financial Services through a VAT in Mexico." He is also a graduate of the University of Texas at Austin's McCombs School of Business and of the Instituto Tecnológico de Estudios Superiores de Monterrey (Tec de Monterrey), obtaining two distinct MBA degrees from the respective institutions.

Mr. Hernández-Pulido has served on the Board of Directors for both public and private organizations in Mexico. He is an active member of the State Bar of California, American Bar Association, the Barra Mexicana de Abogados (Mexican Bar), San Diego County Bar Association, the Harvard Club of Mexico and Harvard Law School Alumni Association - Mexico. Mr. Hernández-Pulido is a past Chair of the International Committee of the Taxation Section of the State Bar of California.  Recently, he was elected to the Executive Commission of the International Section of the California State Bar effective in September of 2011.

Mr. Hernández- Pulido is a member of the Board of Friends of Vista Hill and the U.S. Board of Fondo para la Paz, I.A.P. and is the U.S. tax counsel (pro-bono) for the Mexican Red Cross.

Recent News Coverage

• Broderick, Pat. "Homes With Million Dollar Views Selling for $300,000 in Mexico", San Diego Business Journal, August 7, 2006

Recent Articles/Publications

• "What Happens in Mexico...is Taxed in the U.S.! How the New FATCA Provisions Affect Mexican Residential Trusts," March 2010
• “Mexico’s New Tax on Cash Deposits and its Creditability Under IRC Section 901," Practical Mexican Tax Strategies, May/June 2008 and Practical Latin American Tax Strategies, June 2008
• "Doing Business in Mexico", Interviewed by Leslie Stevens-Huffman, SmartBusiness San Diego, January 2008
• FAQ's - Investing in Mexican Real Estate
• Client Update: Mexico's Flat Tax (IETU) and How it Affects U.S. Investors in Mexican Real Estate Projects
• The 10 Most Relevant 2007 Mexican Tax Reforms
• "What Happens In Mexico . . . Has To Be Reported To The IRS! Mexican Residential Trusts and the Reporting Requirements Under IRC Section 6048," August 15, 2006
• Mexican Residential Trusts and the Reporting Requirements of Section 6048
• How Do You Say "FIRPTA" In Spanish? A Comparative International Tax Analysis For Foreign Investors Of U.S. & Mexican Real Estate
  

Recent Seminars and Speeches

• "Advising International Clients in Time of Opportunities," Procopio Real Estate Brokers Event, San Diego, CA, May 20, 2009
• “New U.S.-Mexico Cross Border Corporate Tax Challenges,” Strafford Teleconference, June 3, 2009
• “Inbound Real Estate Investment in the Era of the Declining Dollar,” Annual Meeting of the California Tax Bar & California Tax Policy Conference, San Francisco, CA, November 6, 2008
• “Alternatives for Foreign Persons Investing in Real Estate in the US”, Fiscal Commission of the Public Accountants Association of Baja California, Tijuana, Mexico, July 2008
• Investing in Mexican Real Estate Conference 2007, February 2007
• Investing in Mexican Real Estate Conference 2006, February 2006