2 South Biscayne Boulevard, Suite 1900
Miami, Florida 33131
Guillermo J. Fernández-Quincoces is of counsel and a tax lawyer with Foley & Lardner LLP. Mr. Fernández-Quincoces focuses his substantial practice on estate and trust planning and administration, business tax and transactional practice, charitable planning and giving, international transactions and taxation, and tax-exempt entities and charitable organizations. He is a member of the Taxation, Transactional & Securities, International, Latin America, and Estates & Trusts Practices.
Mr. Fernández-Quincoces’s experience includes representing clients in restructuring life insurance planning, estate tax audits, family estate planning transactions involving complex valuation issues, private letter ruling requests before the IRS involving complex estate, gift and generation-skipping tax issues, private letter rulings on the tax effects of abandoning U.S. permanent resident's visa, probate court proceedings involving the reformation, acceptance and removal of trusts and trustees. He has represented clients in international and general tax law (inbound and outbound U.S. tax planning), commercial law, international cross-border transactions, as well as purchasers in governmental privatizations. Mr. Fernández-Quincoces has also represented high-net-worth U.S. and non-U.S. citizens in connection with domestic and international estate planning and wealth preservation, including asset protection, income, gift, estate and generation-skipping tax planning, probate and estate administration, trust administration, prenuptial agreements and pre-immigration income and estate planning and off-shore trust planning. He has experience establishing tax efficient offshore trusts with U.S. and foreign beneficiaries. Some of these trusts have been audited by the IRS field personnel and were the subject of a favorable technical advice memorandum by the IRS National Office as well as establishing complex Dutch, and U.K.-based structures for both international clients and U.S. companies seeking treaty benefits, preparing and obtaining favorable private letter rulings on "portfolio debt" issues. Mr. Fernández-Quincoces has acted as the lead attorney in a nine-figure merger among a number of companies that were privately held by one client, and a publicly listed REIT. He has represented Fortune 100 companies (in the foodstuffs and leisure industries) in setting up operations in each of the major countries in South America, selection of tax and entity structure of the operations in each of the applicable countries and coordination of such structuring with local counsel and in-house tax departments and/or general counsel. He also has a working knowledge of aspects of civil law in various South American countries. He has acted as tax and general counsel for a local cigarette manufacturer and its majority stockholder as well. He is currently working with Mexican counsel on formulating the most tax efficient manner for the nine figure recapitalization of the debt of a Mexican entity.
|Areas of Practice||1) Estates & Trusts, 2) Latin America, 3) Taxation and 4) Transactional & Securities|
|Law School||Boston College Law School|
|Education||St. Peter's College (B.S., 1970) Harvard University (M.B.A., 1974)|
|Bar Member / Association||State Bar Of Florida|
|Most recent firm||Foley & Lardner LLP|
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Celia Roady is a partner in Morgan Lewis's Tax Practice.Ms. Roady has published extensively in various journals on exempt organizations.