Patrick 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.
Patrick was a summer associate with the IRS District Counsel (Treasury Dept.).
Representative Matters
1. 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.
2. Advise US and international investment funds regarding tax preferred structures for joint US-Latin American land investment, private equity investment, cross border financing and repatriation of real estate profits.
3. Advise foreign financial institutions (non-US), foreign entities and their advisors and employees regarding the application, strategic decisions and implementation of the federal tax law, Foreign Account Tax Compliance Act.
4. 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.
5. Represents various foreign families and individuals regarding pre-immigration and pre-expatriation planning to avoid and/or limit US income, estate and gift tax consequences prior to: (a) immigrating into and taking up tax residency or domicile in the US or (b) expatriating from the US.
6. Represents several international income and estate tax audits before the IRS, including representation before the US Tax Court.
7. Assists numerous US 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.
8. Represents various Mexican, Latin American, Asian, South Pacific and European manufacturing, technology and agricultural companies with US and worldwide joint venture, distribution and sales companies.
9. Assists multiple Latin American real estate clients regarding private equity investment, financed sales and joint ventures with US and Latin American individual and institutional investors.
10. Assists various multi-million dollar Mexican real estate land owners with US joint venture real estate developments.