Patrick W. Martin

As the leader of the firm's tax team, Patrick W. Martin advises clients on a variety of tax related matters including international tax planning and related international law matters. Patrick’s practice focuses on representing foreign clients, multi-national families, international athletes, entertainers and entertainment groups in worldwide investments and financing structures, international tax treaty planning strategies and planning worldwide income, estate and inheritance tax. He is also experienced in resolving and planning for international tax controversies and developing international wealth preservation structures.

Representative Matters

• Represents non-U.S. persons in suits for refunds of taxes in the U.S. Court of Federal Claims. He was successful in a single tax refund case for a non-resident individual and negotiated a tax recovery of US$13.3M million in 2015.
• 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 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.
• 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.
• 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 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.
• Represents several international income and estate tax audits before the IRS, including representation before the US Tax Court.
• 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.
• 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.
• 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.
• Assists various multi-million dollar Mexican real estate land owners with US joint venture real estate developments.