Todd N. Rosenberg

Phone:  305.665.3311
tnr@pnrlaw.com
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Practice Areas
International and Domestic Taxation
Trust and Estate Planning

Experience
Todd concentrates his practice in the area of U.S. income, gift and estate taxation, as well as international and domestic trust and estate planning. His representative experience includes:

  • Representing non-U.S. person clients in relation to tax planning and structuring associated with passive and active business investments within the United States;
  • Representing U.S. person clients in relation to tax planning and structuring associated with passive and active business investments outside of the United States;
  • Assisting clients with their respective domestic estate planning;
  • Assisting clients with their respective international trust planning and related structuring;
  • Representing individuals and families in relation to pre-immigration tax planning;
  • Representing U.S. clients participating in the 2009 Offshore Voluntary Disclosure Program, the 2011 Offshore Voluntary Disclosure Initiative, and the Offshore Voluntary Disclosure Program announced by the Internal Revenue Service on January 9, 2012;
  • Representing foreign trustees in identifying and complying with U.S. Federal tax and reporting requirements in connection with trusts involving U.S. person family members of multijurisdictional families;
  • Implementation of planning strategies to reorganize trust structures to be efficient from a U.S. Federal tax perspective;
  • Assisting foreign individuals in structuring the acquisition of U.S. real estate; and
  • Representing clients who intend to expatriate from the U.S. by relinquishing their U.S. citizenship or U.S. lawful permanent resident status.

Bar Admissions
2001, Florida Bar

Education
2001, J.D., cum laude, Nova Southeastern University Shepard Broad Law Center, Nova Southeastern University Law Review, 2000-2001.
2006, LL.M., Taxation, University of Miami
1998, B.A., Penn State University

Professional & Community Involvement
Member, Florida Bar (Real Property, Probate and Trust and Tax Law sections)
American Bar Association
Greater Miami Tax Institute (former President)

Recent Speeches & Articles

Todd has lectured for various tax, trust and estate planning groups such as Alpha Kappa Psi, STEP Grand Cayman, the Transnational Taxation Network, The BVI Association of Registered Agents, STEP British Virgin Islands, the Estate Planning Council of Greater Miami, CIBC Bank and Trust Company (Cayman) Limited and the annual International Tax Conference presented by the Tax Section of the Florida Bar and the Florida Institute of Certified Public Accountants.  Further detail in relation to recent presentations is as follows:

Speaker, “U.S. Tax Considerations for Multi-Jursidictional Family Trust Planning”, Estate Planning Council of Greater Miami, February 19, 2015

Speaker, “U.S. Tax Considerations for Multi-Jursidictional Family Trust Planning”, BVI Association of Registered Agents and STEP British Virgin Islands, February 12, 2015

Speaker, “Foreign (Non-US) Investment in U.S. Real Estate,” Transnational Taxation Network Conference, Miami, FL, May 1, 2015

Guest Speaker, 2015 University of Miami Tax Program class entitled “Representing High Net Worth Individuals, January 15, 2015

Co-Speaker, “Residence and Domicile—Off the Beaten Path,” Florida Bar 33rd Annual International Tax Conference, Miami, FL, January 8, 2015

Co-Speaker, “Pre-Immigration Tax Planning – Traditional and Alternative Approaches”, Greater Miami Tax Institute, August 13, 2014

Speaker, “Not Your Father’s U.S. Pre-Immigration Tax Plan,” Transnational Taxation Network Conference, Miami, FL, May 1, 2014

Speaker, “U.S. Tax Considerations for Multi-Jursidictional Family Trust Planning”, STEP Cayman, April 17, 2014