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Enrique Hernandez-Pulido

Enrique Hernandez-Pulido

Partner

Enrique Hernandez-Pulido

Admissions

California;
Mexico (Nationwide)

Languages

Spanish


Address

525 B Street, Suite 2200, San Diego, CA 92101

Office Tel.

619.515.3240

Fax

619.744.5440

Overview

Enrique provides international tax planning and related international matters, particularly Mexican and U.S.-Mexican legal matters. Enrique represents clients in the development of business transactions, worldwide investment and financing structures, planning for worldwide income and estate and inheritance taxes. He serves on Procopio’s Management Committee, leads its Latin America-U.S. Cross-Border practice and co-leads its Beer, Wine and Spirits practice.

Enrique worked for ten 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, Enrique was an associate attorney for the law firm of Bryan, González Vargas y González Baz in Mexico City. Before relocating to San Diego, he was on the faculty at ITAM (Instituto Tecnológico Autónomo de México) in Mexico City teaching advanced courses in tax law in its School of Law.

Enrique is a past chair of the International Law Section and of the International Tax Committee of the Tax Section of the California State Bar and of the International Law Section of the San Diego Bar Association. He is a member of the Practice Council for NYU’s School of Law’s LLM in International Tax and of the Council for the Center for U.S.-Mexican Studies of the University of California, San Diego.

Enrique has published articles on tax law and policy and has directed several tax related professional thesis. He is a frequent speaker at international tax events through Latin America, Mexico and the U.S., including those organized by the International Fiscal Association (IFA), Society of Trust and Estate Practitioners (STEP), the Mexican Bar Association, the California Bar Association (now California Lawyers Association), the New York Bar Association, the Mexican Institute of Public Accountants, the Inter-American Association of Public Accountants and many other national and regional lawyer and CPA associations, among others. He is a prolific writer of articles and essays on international tax topics and has been the subject of various media interviews in Mexico and the U.S.

  • Represents 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.
  • Structures 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.
  • Represents Mexican manufacturing and service companies with respect to their U.S. matters, subsidiaries and operations.
  • Designs, structures and implements 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.

  • Best Lawyers®, Tax Law, 2021-present
  • Top 50 Latino Leaders of Influence, San Diego Business Journal, 2022
  • Super Lawyers® Rising Star, International Law, 2015
  • Special Certificate of Merit for Excellence in Research and Writing – Master’s Thesis: “Alternatives for Taxing Financial Services through a VAT in Mexico”

  • LLM/ITP (International Taxation and Tax Policy), Harvard Law School, 1995
  • LLD, Universidad Iberoamericana, 1992
  • MBA, University of Texas at Austin McCombs School of Business
  • MBA, Instituto Tecnológico de Estudios Superiores de Monterrey (Tec de Monterrey)

  • Panelist. “The Tax Reform that Mexico Needs,” Procopio International Tax Institute, San Diego, CA, May 26, 2023.
  • Panelist. “The Use of Artificial Intelligence in the Tax Practice,” Procopio International Tax Institute, San Diego, CA, May 25, 2023.
  • Panelist. “Cross-Border Trust Planning and Tax Compliance,” Nevada Trust Conference, April 26, 2023.
  • Presenter: “Mexico’s Presidential Election – New Strategies for New Times,” STEP Orange County 8th Annual Institute On Tax, Estate and the World Economy, Newport Beach, Ca, February 4, 2019.
  • Co-author. “Eleven Key Considerations for the Prudent Prospective Luxury Home Purchaser,” May 18, 2018.
  • Moderator. “The U.S. Tax Reform’s Impact on Estate and Inheritance Tax Planning for Multinational Families,” USD Procopio International Tax Institute, November 2, 2018.
  • Moderator. “Mexico Challenges Toward the U.S. Tax Reform.  What Has Been Done and What Must be Done?”  USD Procopio International Tax Institute, November 1, 2018.
  • Moderator. “Latin American Family Offices Boom and their International Tax Challenges,” USD Procopio International Tax Institute, San Diego, October 26, 2017.
  • Moderator. “Estate Planning for Latin American Families in a World Post Amnesty and CRS/FATCA,” USD Procopio International Tax Institute, San Diego, October 26, 2017.
  • Co-presenter. “An Open Dialogue on the Challenges of Global Practice,” Transitional Law Summit: International Law in the 21st Century, Los Angeles, Ca, November 4, 2016.
  • Moderator. “Offshore and Amnesty Programs – Update on CRS and FATCA Implementation in Latin America,” USD Procopio International Tax Institute, October 21, 2016.
  • Moderator. “New International Estate and Tax Planning Strategies for Latin American Families,” USD Procopio International Tax Institute, October 20, 2016.
  • Moderator. “BEPS Implementation in Mexico,” USD Procopio International Tax Institute, October 20, 2016.
  • Moderator. “State Aid: A Plague on All Their Houses” USD Procopio International Tax Institute, October 20, 2016.
  • Co-presenter. “Business Perspective and Analysis – The Five Year Vision,” USD Procopio International Business Summit, San Diego, CA, March 18, 2016.
  • Co-presenter. “Case Study – Challenges: Adapt, Adjust and the Pedal to the Metal,” USD Procopio International Business Summit, San Diego, CA, March 18, 2016.
  • Co-presenter. “How to Promote and Market Your Products/Services in the U.S.” USD Procopio International Business Summit, San Diego, CA, March 17, 2016.
  • Moderator. “PRODECON, Experiences and Challenges after 4 Years,” USD Procopio International Tax Institute, San Diego, CA, October 22, 2015.
  • Moderator. “Estate Planning for Latin America,” USD Procopio International Tax Institute, San Diego, CA, October 22, 2015.
  • Moderator. “Mexican 2016 Tax Reform and Oil & Gas Update,” USD Procopio International Tax Institute, San Diego, CA, October 23, 2015.
  • Co-presenter. “Practice Focus: US/Mexico Planning,” The Inaugural STEP USA Conference, San Diego, CA, June 4, 2015.
  • Panelist. “Prevencion del fraude medlante el Intercambio de Information entre las Administraciones Tribitarias,” International Fiscal Association (IFA), Santo Domingo, Dominican Republic, May 21, 2015.
  • Moderator. “International Tax Update: Mexico’s Tax Reform,” USD Procopio International Tax Institute, October 31, 2014.
  • “Cross Border Asset Protection in the 21st Century,” USD Procopio International Tax Institute, October 30, 2014.
  • Moderator. “International Tax Audits & International Tax Appeals,” USD Procopio International Tax Institute, October 30, 2014.
  • Moderator. “Cross Border Tax Planning and Corporate Structuring Considerations for US Companies Investing in Energy Projects in Mexico,” USD Procopio International Tax Institute, October 30, 2014.
  • Panelist. “Conclusions on Energy Reform: Opportunities for U.S. Businesses,” San Diego, CA, September 19, 2014.
  • Co-presenter. “Cross Border Tax Considerations for Financing Energy Projects in Mexico,” San Diego, CA, September 19, 2014.
  • Moderator. “Judicial Review of Tax Laws: What is the Correct Standard for It?,” USD, School of Law – Procopio International Tax Institute 2013, San Diego, CA, October 24-25, 2013.
  • Moderator. “Private Sector Commentary on Proposed Mexican Tax Reform,” USD, School of Law – Procopio International Tax Institute 2013, San Diego, CA, October 24-25, 2013.
  • Contributing author. “Mexico’s Proposed Tax Reform: International and Cross border Highlights,” October 2013.
  • Moderator. “International Tax Update: Mexico’s Tax Reform,” USD, School of Law – Procopio International Tax Institute 2013, San Diego, CA, October 24-25, 2013.
  • Speaker. “Important International Tax Issues for Cross-Border Business and Foreign Investors,” State Bar of California, International Law Section, San Diego, CA, May 31, 2013.
  • Author. “Now You See It, Now You Don’t! The Demise of the Mexican Residential Trust (Fideicomiso), International Tax Consequences & Planning Considerations.” April 29, 2013.
  • Author. “Preparing your Mexican Investments for the Jump into the 2013 Tax Cliff,” September 5, 2012.

  • California Lawyers Association, International Law and Immigration Section, Member of the Board of Representatives, 2021
  • Practice Council for the International Tax Program of the New York University (NYU) School of Law, Member
  • Grupo Editorial Expansion, S.A.P.I. de C.V., Board of Directors
  • American Bar Association
  • Barra Mexicana de Abogados (Mexican Bar)
  • Harvard Law School Alumni Association, Mexico
  • San Diego County Bar Association
  • The California State Bar
    • Chair, International Law Section
    • Taxation Section International Committee Past Chair
    • International Section Treasurer and Executive Commission
  • Center for U.S.-Mexican Studies (USMEX) at the School of Global Policy and Strategy at the University of California San Diego, Advisory Board Member
  • Colibri Scholarship Fund, Board of Directors