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.).
- 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.