2018 Family Office Tax Roundtable

Alejandro (Alex) Ruiz advises clients on the tax aspects of complex domestic and cross-border transactions and on the formation and operation of private equity funds, with an emphasis on mergers and acquisitions (M&A), joint ventures, growth capital, continuation vehicles, and divestitures involving private equity sponsors and private companies.

Alex’s clients include private equity funds, private and public companies, venture capital funds, individuals, hospitals, physician practices, ambulatory surgery centers (ASCs), strategic investors, and tax-exempt organizations. He has extensive experience advising buyers, sellers, founders, and joint venture partners in transactions involving healthcare companies, particularly in the development of tax efficient financial arrangements and transaction structures designed to comply with federal and state healthcare laws.

Additionally, Alex has experience advising on the tax aspects of fund sponsor compensation arrangements, management co-investments, and incentive equity compensation, as well as drafting equity purchase and profits interest agreements and complex bonus plans.

Alex speaks regularly at the firm’s industry and legal symposia on a range of subjects, including the impact of tax reform on private equity and M&A, drafting and negotiating tax provisions in transaction documents, mastering the tax aspects of partnership transactions, qualified small business stock, and structuring private equity transactions.

Evan Walters concentrates his practice on the tax aspects of complex transactions, with a particular focus on issues involving pass-through entities and tax planning for closely-held businesses and high-net-worth individuals. He also guides clients on the formation of family offices and related tax issues.

Evan also has extensive experience in tax controversy matters and has advised clients through Internal Revenue Service (IRS) audits and litigation in Tax Court and Federal District Court. He is an editor and regular contributor to the Firm’s Tax Controversy 360 blog.

Gary C. Karch advises clients on the federal income tax aspects of partnership and limited liability company transactions, including acquisitions, investments, joint ventures and restructurings.

Gary is also a certified public accountant.

Kevin Hall concentrates his practice on the tax aspects of complex domestic and cross-border transactions and the formation and operation of private equity funds and family offices. Kevin has extensive experience advising buyers, sellers, and joint venture partners on the tax aspects of complex transactions, with a special emphasis on transactions involving healthcare companies. He also regularly represents fund sponsors in structuring funds across a variety of strategies, including buyout, real estate, credit, growth equity and venture capital, co-investment, fund-of-funds, and secondaries.

Kevin graduated first in his law school class and was a member of the Florida Law Review. He was an adjunct tax professor at the University of Miami School of Law, a Graduate Editor of the Tax Law Review at New York University School of Law, and a legal intern at the IRS Office of Chief Counsel.

Kevin holds an inactive certified public accounting license.

Michael J. Bruno advises multinational companies, funds, single family offices, and entrepreneurs on sophisticated US and international tax planning and transactions. He has extensive experience in advising clients in the technology, healthcare, life sciences, digital health, consumer products, FinTech and cryptocurrency, and sports and entertainment industries.

Michael regularly advises clients on mergers, acquisitions, restructurings, joint ventures, and divestitures in various business contexts. He has assisted clients with many international tax issues, including navigating anti-deferral (controlled foreign corporation (CFC) and passive foreign investment company) regimes, foreign tax credit planning, export planning, treaty planning, intellectual property migrations, tax-efficient cash repatriation strategies, and post-acquisition integration and implementation.

Michael also regularly advises entrepreneurial families on strategies for minimizing US income taxation with respect to their closely held businesses and investments, including qualified small business stock planning. Through comments and a presentation, Michael advocated on behalf of The Florida Bar Tax Section for Congress, the Internal Revenue Service, and the US Department of the Treasury to afford the Section 250 deduction to electing Section 962 shareholders that earn Global Intangible Low-Taxed Income, as well as reinstating the repeal of Section 958(b)(4) for CFC downward attribution.

He has written numerous articles on international tax planning and frequently submits comments on statutory and regulatory promulgations. As a strong proponent for pro bono legal services, Michael founded the Transactional Equal Justice Program with Legal Services of Greater Miami, which offers free legal advice to nonprofits and low-to-moderate income small business owners to help them launch a business.

Patrick J. McCurry concentrates his practice on the corporate and tax aspects of complex business and investment transactions, with a particular focus on transactions involving single-family offices, private equity funds and other financial sponsors (on both buy and sell-side), emerging businesses, partnerships and strategic joint ventures, limited liability companies and closely held corporations.

Patrick has extensive experience in working with single-family offices in connection with the formation and/or restructuring of family offices and private trust companies, the creation of investment funds, the establishment of incentive equity programs for key employees and related income tax planning.  He also routinely works on complex tax planning for high-net-worth individual and families, tax structuring healthcare services transactions and tax controversy matters.

Patrick is Co-Leader of the Firm’s Closely Held and Passthroughs Affinity Group.

Ranked as “Band 1” by Chambers High Net Worth in its national Family Offices & Funds Restructuring category, clients praise Patrick for being “a lucid communicator, even of incredibly complex tax and legal concepts.” Other clients note that Patrick “brings a level of knowledge and expertise in family office and partnership taxation” and he “never brings up an issue without thinking about multiple potential solutions.”

While in law school, Patrick served as an extern for the Honorable Ronald A. Guzman, US District Court for the Northern District of Illinois. He also was a member of the Loyola University Chicago Law Journal.

Sandra McGill focuses her practice on international tax planning. Sandra works with US and non-US multinational companies, public and private as well as high net worth individuals and family businesses. Sandra has extensive experience advising clients on a broad range of cross-border tax issues, including the following:

• Foreign tax credit planning
• Subpart F and PFIC anti-deferral rules
• Source of income and withholding tax issues and compliance, including obtaining Treaty relief
• Foreign currency recognition rules under Sections 985-989
• US trade or business or local country permanent establishment (PE) issues
• Section 367 and other subchapter C issues related to cross-border restructurings, acquisitions and financings, including issues with respect to intellectual property

Sandra works with an extensive network of non-US lawyers on developing multi-jurisdictional business structures such as centralized sales and services and finance company structures.

Sandra is a co-founder of Tax in the City®: A Tax Roundtable, which consists of tax professionals who meet regularly to discuss substantive tax issues in a confidential setting.

Steven Hadjilogiou focuses his practice on tax optimization of business operations and investments with a specific emphasis in the areas of international tax and real estate. Steven provides advice on international inbound and outbound tax planning for multinational companies, family offices, private equity and ultra-high net worth individuals. He also advises funds, family offices and ultra-high net worth individuals in connection with complex real estate structuring and investment issues, including in the areas of opportunity zone funds, 1031 transactions and qualified small business stock.

Steven has represented various Fortune 500 companies and major privately held businesses in their tax planning and supply chain projects, and also has substantial experience advising on transfer pricing, tax-related intellectual property matters, Subpart F, GILTI, foreign investment in US real property and outbound investment in real property. Steven also advises clients on pre-immigration planning and cross-border wealth succession. Steven has also worked on the taxation of partnerships and corporations, mergers & acquisitions and international corporate reorganizations.

Since 2013, Steven has been an adjunct professor of International Inbound Taxation at the University of Miami Graduate Tax Program. He is the co-chair of the annual Florida Bar/FICPA International Tax Conference. Steven has written numerous articles and presented on topics related to tax. He was a primary drafter of the amicus curiae brief submitted to the US Supreme Court on behalf of the Florida Bar Tax Section in Knight v. Commissioner in 2008.

Thomas (Tom) P. Ward advises high-net-worth individuals and business owners on the income tax, corporate and compliance aspects of complex business and investment transactions, with a focus on family office management companies, private investment funds and complex incentive equity programs.

Tom has extensive experience in establishing and working with family offices and investment entities, ranging from first-generation entrepreneurs to multi-generational families, with net worth from $40 million to many billions of dollars, including a number of individuals listed in the Forbes 400. Tom works closely with the entire advisor team to implement the optimal structure for a particular situation and has extensive experience working with private trust company, airplane, transfer tax and security law considerations.

Tom is a frequent speaker on trends impacting family offices and high-net-worth individuals.

Ranked as “Band 1” by Chambers High Net Worth in its national Family Offices & Funds Restructuring category, clients praise Tom for being “a very thoughtful and knowledgeable attorney that truly understands the needs of an SFO. Tom's approach is very thoughtful and always tries to find creative ways to accomplish his client's goals."

While in law school, he was an editor of the Michigan International Law Journal.