Seth J. Entin

Seth J. Entin

Seth J. Entin concentrates his practice in the area of federal income taxation, with an emphasis on international taxation. Seth has been listed in the Best Lawyers in America, Chambers USA: America's Leading Lawyers for Business and The Legal 500 US and is an Adjunct Professor of Taxation at the University of Miami School of Law. Seth speaks regularly at local, national and international tax seminars and conferences and is the Assistant Director for International Tax of the Florida Bar Tax Section.

Areas of Concentration

· Tax-efficient structures for foreign operations and investments by U.S. companies and individuals

· Tax-efficient structures for investments by foreign companies and individuals in U.S. operating businesses, real estate and securities

· Cross-border acquisitions, dispositions, restructurings, asset transfers and joint ventures

· Cross-border private equity transactions

· Tax-efficient structures for cross-border exploitation of intellectual property and cross-border e-commerce

· Pre-immigration tax planning

· Securing IRS private letter rulings

· Offshore Voluntary Disclosure

Professional & Community Involvement

· Adjunct Professor of Taxation, University of Miami School of Law, 2005 - 2006; 2006 - 2007; 2007 - 2008; 2008 - 2009

· Editorial Board, Corporate Business Taxation Monthly (CCH)

· Board of Directors, Commerce & Professions Division, Greater Miami Jewish Federation

· Chair, Outbound Tax Committee, Florida Bar Tax Section, 2005-2006, 2006-2007, 2007-2008

· Member, Professional Advisory Committee, Foundation of Jewish Philanthropies

· Assistant Director, International Tax, Florida Bar Tax Section, 2008 - 2009

Awards & Recognition

· Listed, Best Lawyers in America, 2007-2010

· Listed, Chambers & Partners USA Guide, an annual listing of the leading business lawyers and law firms in the world, 2007, 2008 and 2009 editions

· Listed, Legal 500 US, 2009 Edition

Articles, Publications, & Lectures

Articles

· Co-Author, "IRS Issues Critical Guidance Regarding Reporting of Foreign Bank and Financial Accounts," Practical US/International Tax Strategies, July 2009

· Author, "U.S. - New Regulations Address Application Portfolio Interest Exemption to Foreign Partners," Practical US/International Tax Strategies, April 2007

· Author, "IRS to Expand Tax Exemption for Interest Income Earned by Foreign Investors," Derivatives, August 2006

· Author, "IRS Revises Circular 230 Final Regulations, Easing Several Requirements," Derivatives, June 2005

· Author, "Partnerships and the Portfolio Interest Exemption," Tax Notes, September 1, 2003

· Author, "The Treatment of Partnerships Under the U.S. Portfolio Interest Exemption: Inconsistencies and Opportunities," Tax Notes International, July 21, 2003

· Co-Author, "Structural Science," The Daily Deal/The Deal, June 2, 2003

Lectures

· Panel Chair, "Real Estate: Investment in Distressed Mortgages and Other Real Estate Assets Across Borders," International Bar Association/American Bar Association, U.S. and Latin American Tax Planning Strategies Conference, Miami, Florida, June 2009

· Speaker, "The Future of Deferral under the Obama International Tax Proposals," Florida Bar Tax Section Technical Webinar for Federal Tax, June 2009

· Speaker, "Seeking Relief Abroad: The Use of Losses of Foreign Subsidiaries and Permanent Establishments," Tax Considerations in the Global Financial Crisis, Bonn, Germany, May 2009

· Speaker, "Hybrid Entities--What's Left?," ABA Section of Taxation 2009 May Meeting, Washington, D.C., May 2009

· Speaker, "Trends of Tax Courts in the Resolution of International Tax Matters," Colegio de Contadores Publicos de Mexico International Transactions Conference, Miami, Florida, March 2009

· Speaker, "Structuring Distressed U.S. Real Estate and Mortgage Investments for Offshore Funds," 27th Annual International Tax Conference, Miami Florida, January 2009

· Speaker, "Structuring Distressed Real Estate Fund Investment in the U.S.," International Wealth Planning for Brazilian and Mexican Families and Entrepreneurs Conference, Miami and New York, October 2008

· Panel Chair, "Cross Border Service Arrangements," International Bar Association/American Bar Association, U.S. and Latin American Tax Planning Strategies Conference, Miami, Florida, June 2008

· Speaker, "Challenges When Structuring Cross-Border Transactions and Potential Solutions," AIJA Conference on The Challenges of Doing Business in Multiple Jurisdictions, Miami, Florida, May 2008

· Speaker, "Computing the Gain from the Sale of CFC Shares under Sec. 1248," presented at the U.S. International Tax Reporting and Compliance seminar, Fort Lauderdale, Florida, January 2008

· Speaker, "The Expanding Universe of Private Equity Funds: Structuring the Acquisition of Foreign Target Companies," Florida Bar/Florida Institute of Certified Public Accountants 26th Annual International Tax Conference, Miami, Florida, January 2008

· Panel Chair, "High profile executives - Types of Remuneration - Stock Plan and Stock Option Plans/Profit Sharing Mechanisms - Tax Aspects," International Bar Association, Tax Aspects of Cross-Border Transactions in Latin American Markets, Sao Paulo, Brazil, May 2007

· Panelist, "U.S. Model Income Tax Treaty," American Bar Association Section of Taxation 2007 May Meeting, Washington, DC, May 2007

· Panelist, "Alternative Structures for Foreign Investment in U.S. Real Estate," American Bar Association Section of Real Property, Probate & Trust Law, Denver, Colorado, October 2006

· Panelist, "Home Sweet Home Away From Home," American Bar Association Section of Taxation, Committee on U.S. Activities of Foreigners and Tax Treaties, Denver, Colorado, October 2006

· Speaker, "The Challenge of the Multinational Family and Pitfalls of Foreign Investing ," Estate Planning Council of New York City, October 16, 2007

· Speaker, "International Tax Aspects of the Internet and E-Commerce," International Income Tax and Estate Planning Conference, Miami, Florida, October 12, 2007

· Speaker, "The New U.S. Model Treat--Selected Topics," Florida Bar Tax Section Teleconference, May 31, 2007

· Speaker, "U.S. Persons Investing in Real Estate Abroad," Florida Bar/Florida Institute of Certified Public Accountants 25th Annual International Tax Conference, Miami, Florida, January 2007

· Speaker, "Transfers of Goodwill and Other Intangible Property," Maryland Bar Association/Maryland CPA Society, Advanced Tax Institute, Baltimore, Maryland, November 2006

· Panelist, "You Can Run but you Cannot Hide Forever, Reporting Requirements and Voluntary Disclosure," International Bar Association Annual Conference, Chicago, Illinois, September 2006

· Speaker, "Selected Current International Tax Developments," Florida Bar Tax Section Annual Meeting, July 2006

· Speaker, "New Developments in Inbound & Outbound Financing," Florida Bar Tax Section Annual Meeting, July 2006

· Speaker, "Current U.S. International Tax Developments," Baker Tilly International Tax Committee, May 2006

· Speaker, "Strategic U. S. Tax Planning for Foreigners...Don't Leave Your Home Country Without It," Greater Miami Jewish Federation Foundation, Miami, Florida, March 23, 2006

· Speaker, "US Tax Planning Opportunities with Holding Companies and Check the Box Rules," T.T.N. Conference, Miami, Florida, February 2006

· Speaker, "When Inbound Becomes Outbound: Foreign Corporations that Become CFCs," Florida Bar/Florida Institute of Certified Public Accountants 24th Annual International Tax Conference, Miami, Florida, January 2006

· Speaker, "Taxation of Gain from the Sale of a CFC," U.S. International Tax Reporting & Compliance Seminar, Council for International Tax Education, January 2006

· Speaker, "Computing the Gain from the Sale of CFC Shares under Sec. 1248," presented at the U.S. International Tax Reporting and Compliance seminar, Miami, Florida, January 2006

· Speaker, "Taxation of United States Persons with Business Operations Abroad," Florida Bar International Law Section, International Income Tax & Estate Planning Seminar, Miami, Florida, October 14, 2005

· Speaker, "Choice of Entity, with an Emphasis on Recent Changes in the Tax Law," Florida Institute of Certified Public Accountants, Accounting & Business Expo, Orlando, Florida, June 2005

· Speaker, "Arranging for Intercompany Transfers of Intangible Property," International Transfer Pricing 101 Seminar, Council for International Tax Education, May 2005

· Panelist, "Structuring Inbound Investments: Tax Considerations," Florida Bar International Law Section, International Investment Symposium, April 2005

· Speaker, "Tax Incentives and Disincentives to Investment in U.S. Real Estate," International Bar Association, Tax Incentives in Latin America Conference, March 2005

· Speaker, "Structuring Foreign Investment in U.S. Real Estate--Effects of New Legislation & Examination of New Techniques," Greater Miami Tax Institute, March 2005

· Speaker, "Tax Planning for the Acquisition or Disposition of a Foreign Business," Committee on International Tax Education, Miami, Florida, January 2005

· Speaker, "Tax Planning for the Ownership, Development and Use of Intellectual Property in the International Arena," Florida Bar/Florida Institute of Certified Public Accountants 23rd Annual International Tax Conference, Miami, Florida, January 2005

· Speaker, "Choice of Entity Revisited After the 2003 Tax Act," Florida Institute of Certified Public Accountants/Florida State University Fall Accounting Conference, Tallahassee, Florida, November 2004

· Speaker, "Special Issues in International Mergers and Acquisitions," Intermediate U.S. International Tax Update, Alliance for Tax, Legal & Accounting Seminars, October 2004

· Speaker, "Arranging for Intercompany Transfers of Intangible Property," International Transfer Pricing 101 Seminar, Committee on International Tax Education, May 2004

· Speaker, "Tax Planning Strategies for the Acquisition & Disposition of a Foreign Business," Florida Bar/Florida Institute of Certified Public Accountants 22nd Annual International Tax Conference, Miami, Fla., January 2004

· Speaker, "Tax-Efficient Financing of Multinational Operations: Opportunities & Challenges," Florida Bar/ Florida Institute of Certified Public Accountants 21st Annual International Tax Conference, Miami, FL, January 2003

· Panelist, "Tax Planning for Latin American Families," 2nd Annual Global Congress - International Tax Planning, Money Laundering & Compliance, sponsored by the St. Thomas University School of Law and the University of Florida School of Law, Miami Beach, FL, December 2002

· Speaker, "Using Cost-Sharing for Funding Offshore IP Development," presented at the "High-Tech Tax Update" Seminar sponsored by the Council for International Tax Education, Boston, MA, July 2002

· Speaker, "Use of Organizational Structure to Maximize Foreign Tax Credit Utilization," presented at the Foreign Tax Credit Update Seminar, New York, NY, June, 2002

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