Patrick W. Martin

Practice Details

• Languages
  Spanish
  Italian
• Firm Information
  Position

  Partner

  Firm Name

  Procopio, Cory, Hargreaves & Savitch LLP
• Representative Cases & Transactions
  Cases

  Representative Matters: Represents various multi-national families in developing worldwide income, estate
  inheritance tax
  international wealth preservation structures including advising
  defending audits by tax authorities.
  Advise US
  international investment funds regarding tax preferred structures for joint US-Latin American l
  investment, private equity investment, cross border financing
  repatriation of real estate profits.
  Represents multiple individuals before the U.S. Tax Court, the U.S. Court of Federal Claims
  the Federal District Courts regarding assessed taxes, penalties
  amounts regarding international income, foreign assets
  foreign accounts.
  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
  negotiated a tax recovery of US$13.3M million in 2015 after the case was filed on appeal to the Federal Circuit.
  Advise foreign financial institutions (non-US), foreign entities
  their advisors
  employees regarding the application, strategic decisions
  implementation of the federal tax law, Foreign Account Tax Compliance Act.
  Represents various foreign families
  individuals regarding pre-immigration
  pre-expatriation planning to avoid
  /or limit US income, estate
  gift tax consequences prior to: (a) immigrating into
  taking up tax residency or domicile in the US or (b) expatriating from the US.
  Represents individuals, trusts, estates
  privately held companies in various international income
  estate tax audits before the IRS, including representation before the US Tax Court, federal District Court
  Court of Federal Claims.
  Represents international entertainers (including various Grammy
  Oscar award winners) regarding tax controversy matters before the IRS, planning considerations of their worldwide incomes, publishing, promotion, concerts, tax-exempt foundations
  sales
  related activities.
  Assists numerous US developers (joint ventures, l
  
  construction development) with Mexican
  Latin America (e.g., Costa Rica
  Guatemala) real estate acquisitions
  development
  structuring global operations, financing, equity investment, repatriation of funds
  tax treaty benefits.
  Assists multiple Latin American real estate clients regarding private equity investment, financed sales
  joint ventures with US
  Latin American individual
  institutional investors.
  Assists various multi-million dollar Mexican real estate l
  owners with purchases, sales
  U.S. financed cross border joint venture real estate developments.