Alfredo R. Tamayo

 squarealfredo Phone:  305.665.3311 art@pnrlaw.com
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Practice Areas
International and Domestic Taxation Estate Planning
Foreign Account Tax Compliance Act (FATCA)

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

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. family members of multicultural families, as well as 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 to be efficient from a U.S. Federal tax and succession planning perspective;

Conducting pre-immigration U.S. Federal tax planning for foreign individuals either temporarily or permanently immigrating to the United States;

Representing clients involved in U.S. Federal income, estate, and Foreign Bank Account Report (“FBAR”) examinations before the IRS;

Representing clients who intend to expatriate from the U.S. by relinquishing their U.S. citizenship or U.S. permanent resident status; and

Reviewing family trust structures in order to identify and implement steps in becoming compliant with FATCA.

Bar Admissions and Other Professional Certifications
2007, Florida Bar
2000, Certified Public Accountant (CPA)

Education
2008,  LL.M., Taxation, Villanova University
2006, J.D., Nova Southeastern University Shepard Broad Law Center
1997, B.S., Accounting, Villanova University

Professional & Community Involvement
Member, Florida Bar (Tax Law section)
Member, Florida Institute of Certified Public Accountants
Member, American Association of Attorney-Certified Public Accountants
Member, Finance Committee, Chaminade-Madonna High School
Contributing Drafter, Comments to Treasury to Proposed Regulations to Chapter 4 of Subtitle A (Sections 1471 through 1474) of the Internal Revenue Code of 1986 (FATCA), on behalf of Florida Bar
Contributing Drafter, Comments to Treasury to Proposed Regulations to Section 6038D (Regarding FATCA Form 8938) on behalf of Florida Bar

Recent Speeches & Articles
Co-Speaker, “FATCA, The OECD’s Global FATCA, and The Fiduciary Industry: Current Challenges and Practical Next Steps,” Florida Bar 33rd Annual International Tax Conference, Miami, FL, January 8, 2015
Co-Speaker, “The Nuts and Bolts of Complying with and Implementing FATCA,“ Florida Bar 31st Annual International Tax Conference, Miami, FL, January 10, 2013
Co-Speaker, “FATCA Update,” Alpha Kappa Psi, Boca Raton, FL, October 26, 2012
Co-author with Shawn P. Wolf, Esq., “Turning Lead to Gold: How to Obtain Pass-Through    Status for “Per Se” Foreign Entities,” The Florida Bar Bulletin, Winter 2013
Co-author with Shawn P. Wolf, Esq., “A ‘Relevant’ Pre-Immigration Tax Planning Issue,” The Florida Bar Bulletin, Spring/Summer 2012

Languages
English and Spanish