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525 B Street, Suite 2200
San Diego, California 92101
Direct Phone: 619.515.3230
Direct Fax: 619.744.5430
patrick.martin@procopio.com
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Partner

Patrick W. Martin

Partner

Admissions
California
District of Columbia
Texas
Foreign Language(s)
Spanish
Patrick W. Martin is the leader of the firm's tax team. His practice emphasizes international tax planning and related international law matters. He represents foreign individuals, multi-national families, companies, international athletes, entertainers, and entertainment groups in such areas as developing worldwide investment and financing structures, international tax treaty planning strategies, planning worldwide income, and estate and inheritance taxes. He helps resolve and plan for international tax controversies and develops international wealth preservation structures to compliment the client’s international investments and business transactions.

Mr. Martin was a summer associate with the IRS District Counsel (Treasury Dept.).

Representative Matters
  • Represents various multi-national families in developing worldwide income, estate and inheritance tax and international wealth preservation structures including advising and defending audits by tax authorities.
  • Advise U.S. and international investment funds regarding tax preferred structures for joint U.S.-Latin American land investment, private equity investment, cross border financing and repatriation of real estate profits.
  • Advise foreign financial institutions (non-U.S.), foreign entities and their advisors and employees regarding the application, strategic decisions and implementation of the federal tax law, Foreign Account Tax Compliance Act.
  • Represents international entertainers (including various Grammy Award winners) regarding tax planning considerations of their worldwide publishing, promotion, concerts, tax-exempt foundations, sales, and related activities.
  • Represents various foreign families and individuals regarding pre-immigration and pre-expatriation planning to avoid and/or limit U.S. income, estate and gift tax consequences prior to: (a) immigrating into and taking up tax residency or domicile in the U.S., or (b) expatriating from the U.S.
  • Represents several international income and estate tax audits before the IRS, including representation before the U.S. Tax Court.
  • Assist numerous U.S. developers (joint ventures, land and construction development) with Mexican and Latin America (e.g., Costa Rica and Guatemala) real estate acquisitions and development; structuring global operations, financing, equity investment, repatriation of funds and tax treaty benefits.
  • Represents various Mexican, Latin American, Asian, South Pacific and European manufacturing, technology and agricultural companies with U.S. and worldwide joint venture, distribution and sales companies.
  • Assist multiple Latin American real estate clients regarding private equity investment, financed sales and joint ventures with U.S. and Latin American individual and institutional investors.
  • Assist various multi-million dollar Mexican real estate land owners with U.S. joint venture real estate developments.
Education
  • JD, University of San Diego School of Law, Thomas More scholar, 1992
  • Studied (International Law – Regimen Jurídico de Los Negocios Internacionales en México), La Escuela Libre de Derecho
Distinctions
  • University of San Diego, School of Law, 2014 Distinguished Alumni Award
  • Citywealth Magazine North American Leaders List (lawyers who represent clients regarding wealth management, tax, estate, trust, or philanthropy advice) – 2010
  • Martindale-Hubbell® AV Preeminent Rating
  • Southern California Super Lawyers® – 2007-2014 (Tax)
  • Southern California's Top Lawyers - 2014
  • The State Bar of California the V. Judson Klein Award – November 2010
  • Top Rated Lawyers – 2012 (Southern California, International Law/International Trade)
  • Top Rated Lawyers – 2014 (Taxation Law)
Community Involvement
  • American Bar Association
  • Fondo Para La Paz – Advisory Board
  • International Fiscal Association
  • San Diego County Bar – Taxation Section – Past Chair
  • The State Bar of California – Taxation Section International Committee Past Chair, International Law Section, Taxation Section Past Executive Committee
  • United States Tax Court
  • University of San Diego School of Law – Alumni Board

Mr. Martin is frequently asked to speak at international tax and law conferences. He has also written extensively on matters of international tax law and a list of published articles can be provided upon request.

Recent News Coverage

Recent Publications
Recent Seminars
  • Moderator. “Corporate Compliance: The Confluence of International Criminal Tax, Money Laundering and the Foreign Corrupt Practice Act (FCPA),” USD, School of Law – Procopio International Tax Institute, San Diego, CA, October 24-25, 2013.
  • Moderator. “Finally FACTA – Before its Implementation – This Time Really?” USD, School of Law – Procopio International Tax Institute, San Diego, CA, October 24-25, 2013.
  • Panelist. “Record Renunciation of U.S. Citizenships; Tax Consequences, Life Changes & Passport,” USD, School of Law – Procopio International Tax Institute, San Diego, CA, October 24-25, 2013.
  • 2013 Annual Meeting of the California Tax Bar and California Tax Policy Conference, November 7-9, 2013.
  • The USD School of Law- Procopio International Tax Institute, San Diego, CA, October 24-25, 2013.
  • 2012 Annual Meeting of the California Tax Bar & California Tax Policy Conference - Keeping Your Clients Out of Trouble – FATCA Compliance, November 1st, 2012.
  • The USD School of Law- Procopio International Tax Institute, San Diego, CA, October 25-26, 2012.
  • “The Twentieth Annual Estate and Gift Tax Conference,” The State Bar of California, San Francisco, CA, March 2, 2012.
  • The USD School of Law- Procopio International Tax Institute, San Diego, CA, October 24-25, 2011.
  • FELABAN – XXX Congreso Latinoamericano de Derecho Financiero, Panama, Panama, “Repercusiones Legales del Foreign Account Tax Compliance- FATCA” Co-panelist: Steven A. Musher, Associate Chief Counsel (International) IRS, October 3, 2011.
  • "The 2011 Offshore Voluntary Disclosure Initiative: How it Works and Who May Benefit," San Diego Chapter of the California Society of CPAs, San Diego, CA, June 17, 2011.
  • The USD School of Law- Procopio International Tax Institute, San Diego, CA, October 4-5, 2010.
  • The USD School of Law- Procopio International Tax Institute, San Diego, CA, October 19-20, 2009.
  • "Planeacion Fiscal Internacional de los Estados Unidos para Inversionistas Mexicanos," Asociación Nacional de Abogados de Empresa, México City, Mexico, August 27, 2009.
  • "Aspectos Prácticos ante la Turbulencia Financiera Mundial," Asociación Nacional de Abogados de Empresa, Querétaro, August 12, 2009.
  • "Aspectos de Tributación Internacional: La Inversión USA-Mex, Reglas Anti-abuso, y USA-Mex International Tax Relevant Issues," Asociación Nacional de Abogados de Empresa, México City, CA, June 29, 2009.
  • Investing in Mexican Real Estate, Puerta Vallarta, Mexico, October 25, 2008.
  • The USD School of Law- Procopio International Tax Institute, San Diego, CA, May 1-2, 2008.
  • "Surprise!  You have a Foreign Trust!" Annual Meeting of the CA Tax Bar and CA Tax Policy Conference, November 2, 2007.
  • Investing in Mexican Real Estate Conference, San Diego, CA, February 17, 2007.
  • The USD School of Law- Procopio International Tax Institute, San Diego, CA, February 15-16, 2007.
  • "Fiscalización de Operaciones Internacionales," March 15-16, 2006.
  • Investing in Mexican Real Estate Conference, San Diego, CA, February 25, 2006.
  • The USD School of Law- Procopio International Tax Institute, San Diego, CA, February 2006.
  • "Growth Strategies- Building Blocks for Successful Ventures," CONNECT, San Diego, CA, January 24, 2006.
  • “The Boogey Man - Informational Reporting of International Transactions and the Hefty Penalty Provisions,” 8th Annual San Diego Tax and Accounting Institute, November 11, 2004.
  • "U.S. International Tax and Legal Implications of Maquiladora Operations," May 2004.
  • "What to do when your client didn't 'Check the Box'?," San Diego County Bar Association Taxation Section, San Diego, CA, September 9, 2003.