Christopher R. Callahan

Phone: 305.665.3311
crc@pnrlaw.com
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Practice Areas
International Taxation
Domestic Taxation
Corporate
Partnership
Estate and Gift Tax Planning
Wealth Preservation

Experience
Mr. Callahan primarily focuses on international tax planning for high net worth individuals, wealth management, subpart F planning, income and estate tax treaty issues, FIRPTA withholding, foreign pension issues, as well as general partnership and corporate taxation. He also has experience in: (i) addressing issues related to FATCA and the IRS Offshore Voluntary Disclosure Program; (ii) advising clients with regard to federal tax controversy issues, and (iii) state and local tax planning.  Mr. Callahan believes strongly in corporate responsibility and has taught at the University of Miami School of Law, LL.M. in Taxation Program regarding advanced international taxation (e.g., “Structuring Latin American Investment”).  In addition, Mr. Callahan is the founder and first participant in the J.D./M.B.A./Tax LL.M. Four-Year Triple Degree Program at the University of Miami.

Recognition
Founder and first participant in the J.D./M.B.A./Tax LL.M. Four-Year Triple Degree Program at the University of Miami.

Bar Admissions
2014, Florida
2013, New York

Court Admissions
2014, United States Tax Court

Education
2013, University of Miami (Tax LL.M.)
2012, University of Miami (M.B.A.)
2011, University of Miami (J.D. magna cum laude)
2007, Tulane University (B.S.)

Professional & Community Involvement
Irish American Bar Association of Florida – President
Florida Bar Tax Section – Assistant Director of the Education Committee
International Fiscal Association (IFA) – Member
American Bar Association (ABA) – Member
Florida State Bar Association – Member
New York State Bar Association – Member

 

Corporate Social Responsibility
Adjunct Professor, University of Miami School of Law, “Structuring Latin American Investment”

Presentations
“Recent Developments in International Inbound Taxation,” Florida Bar Tax Law Section, Ullman Year in Review 2016, Amelia Island, Florida, 4 July 2016.

Co-presenter (with Patricia Brown), “The Application of U.S. Substance-Based Rules to Non-U.S. Taxpayers,” Florida Bar Tax Section, Annual Meeting, 20 May 2016.

Co-presenter (with Shawn Wolf), “Planning for Foreigners Purchasing U.S. Real Estate and U.S. Compliance Rules for Offshore Activities and Accounts,” Florida Institute of Certified Public Accountants (FICPA), CPE Conference, 30 October 2015.

“Recent Developments in International Outbound Taxation,” Florida Bar Tax Law Section, Ullman Year in Review 2014, Amelia Island, Florida, 4 July 2014.

Co-presenter (with Aaron Farmer and Matt Brown), “Are You FATCA Compliant,” Florida Institute of Certified Public Accountants (FICPA), CPE Conference, 19 June 2014.

Secretary and co-presenter (Main Panel), “Subject Two: The Debt-Equity Conundrum,” International Fiscal Association’s (IFA) 66th Annual Congress, Boston, Massachusetts, 30 September – 4 October 2012.