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
- 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
- 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
- Represents international entertainers (including various Grammy Award
winners) regarding tax planning considerations of their worldwide
publishing, promotion, concerts, tax-exempt foundations, sales and
- 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
- 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.