Pedro E. Corona de la Fuente

Pedro E. Corona de la Fuente: Attorney with Procopio, Cory, Hargreaves & Savitch LLP


Professional Summary

Pedro is a Partner in Procopio’s International Tax Group, advising clients in international estate planning, international tax and cross-border mergers and acquisitions. His practice focuses on United States investment structures, cross-border transactions, tax treaty planning, withholding obligations and reporting compliance on international transactions. Pedro brings his clients experience in assisting clients and closely held companies with cross-border transactions involving the U.S., Mexico and other Latin American countries.

Pedro is a frequent speaker on international tax topics and recent tax developments affecting cross-border investments from and into Latin America. He is licensed to practice in California and Mexico, and has an LL.M in International Taxation from the University of Florida. In 2013, Pedro received the International Fiscal Association (IFA) Latin America Academic Award, and currently serves as the President of the YIN Committee of IFA USA.


•2013 International Fiscal Association (IFA) Latin American Academic Award

News Coverage

•Procopio Elevates Partners,” The Daily Transcript, January 16, 2018.
•“Procopio International Tax Associate Becomes First Mexican to Win Esteemed Latin American Academic Award,” LawExchange International, July 15, 2013.
•“Procopio Associate Receives International Award,” SD Metro Magazine, July 5, 2013.


•“Family/Succession Planning for Mexican Owned Assets in the U.S.,” International Fiscal Association - Joint Meeting of the US and Mexico Branches, Washington, D.C., February 20, 2019.
•“Legal Updates for Mexican Companies Doing Business in the United States,” 18th Annual Mexico Economic Review and Political Outlook 2019, Long Beach, January 25, 2019.
•“A Dive into What Do Planners Need to Know When Dealing With our Foreign Neighbors,” California Lawyers Association, The 26th Annual Estate and Gift Tax Conference, San Francisco, March 16, 2018.
•“Global Mobility and Tax Reform in the World Economy,” 46th Annual Conference of the USA Branch of the International Fiscal Association, Houston, TX, February 23, 2018.
•“Inbound Tax Planning After the 2017 Tax Act (or What the H Happened?),” American Bar Association, Section Of Taxation, 2018 Midyear Meeting, San Diego, February 9, 2018.
•“A Dive Into What Planners Need to Know When Dealing With Our Foreign Neighbors,” 2017 Annual Meeting of the California Tax Bar and California Tax Policy Conference, Carlsbad, CA, November 3, 2017.
•“Exchange of Information and Tax Transparency, Including FATCA,” International Fiscal Association - Joint Meeting of the Colombia and USA Branches, Bogota, Colombia, August 25, 2017.
•“Tax Aspects of Foreign Investment in U.S. Residential Real Estate,” 2017 Annual Income Tax Seminar, The State Bar of California, Costa Mesa, CA, June 23, 2017.
•“International M&A - Purchasing Shares in a Foreign Corporation,” Nuts & Bolts Series, San Diego County Bar Association - International Law Section, San Diego, April 21, 2017.
•“Pre-Immigration Tax Planning: Income and Transfer Tax Considerations Before Moving to the U.S.,” STEP Silicon Valley, December 2016.
•“Cross-Border Estate Planning: U.S. and Mexico,” STEP Los Angeles, August 2016.

Latin America-Focused Seminars

•“Reforma Fiscal de los EUA y sus Implicaciones en Mexico”, Ciudad de Mexico, Enero de 2018.
•“Planeacion Patrimonial en los EUA: Consideraciones Fiscales y Legales”, Colegio de Contadores Publicos de Guadalajara, Guadalajara, Mexico, Noviembre de 2016.
•“Alternativas de Inversion en los EUA”, Congreso Regional Fiscal del Instituto del Noroeste de Contadores Publicos, Mexicali, Mexico, Octubre de 2016.
•“Consideraciones Practicas de FATCA: Formas W-8 & Tendencias en Intercambio de Informacion,” Congreso Internacional del Instituto del Noroeste de Contadores Publicos, Ensenada, Mexico, Septiembre de 2016.
•Accion 3 de BEPS: El Futuro de REFIRPES y las Reglas Subpart F de los EUA”, International Fiscal Association, Ciudad de Mexico, Julio de 2016.
•“FATCA y Aspectos Fiscales de Inversiones de los EUA”, Colegio de Notarios del Distrito Federal, Ciudad de Mexico, Febrero de 2016.

Procopio Seminars

•Moderator. “New OECD Guidance Disclosure by Tax Professionals - Exchange of Information and Professional Duties of Confidentiality,” USD Procopio International Tax Institute, November 2, 2018.
•Moderator. “Update on Treaties & the OECD Multilateral Instrument (MLI),” USD Procopio International Tax Institute, November 1, 2018.
•“International Planning for Artists and Sportsmen: Tax and Other Legal Considerations,” USD Procopio International Tax Institute, October 27, 2017.
•“OECD Multilateral Instrument: A New Approach for Applying Bilateral Tax Treaties,” USD Procopio International Tax Institute, October 27, 2017.
•“Cross-Border NAFTA Retirement Plans: Technical Uncertainties and Competent Authority, Federal Social Security taxes while working outside of the home country; Totalization Agreements,” USD Procopio International Tax Institute, October 26, 2017.
•“FATCA & CRS: Consideraciones Practicas,”, USD Procopio International Tax Institute, October 25, 2017.
•“Defending and International Tax Case before the IRS and SAT,” USD Procopio International Tax Institute, October 2016.
• OECD Update & New Reporting Requirements in Mexico and the U.S. for International Investments (Refripes & Single-Member LLCs) USD Procopio International Tax Institute, October 2016.
•“Aplicacion de Tratados Fiscales Internacionales en los EUA”, USD Procopio International Tax Institute, Octubre de 2016.
•“Brazilian Successes in the U.S. - Joga Bonito,” USD Procopio International Business Summit, March 2016.
•“MAP’s: When and How to Start a Mutual Agreement Procedure,” USD Procopio International Tax Institute, October 2015.
•“Selling Mexican Companies when Involving U.S. Shareholders, USD Procopio International Tax Institute, October 2014.
•“Withholding Taxes on Foreign Persons”, USD Procopio International Tax Institute, October 2014.
• Holding Companies, Treaty Benefits and LOB Clauses, USD Procopio International Tax Institute, October 2014.
•“OECD International Tax Initiatives: BEPS Action Plan and Automatic Exchange of Information,” USD School of Law-Procopio International Tax Institute, October 2013.
•“Cross-Border Structures with Hybrid Entities: Avoiding Common Pitfalls,” USD School of Law-Procopio International Tax Institute, October 2013.


•Co-author. “Mandatory Deemed Repatriation: Do You Owe Taxes for 2017 ?” March 26, 2018.
•Co-author. “Nueva Obligacion de Presentar La Forma 5472 Para LLCS Que Tengan Un Solo Socio Extranjer,” 13 de marzo de 2018.
•Co-author. “Post U.S. Tax Reform, What Corporate Structure Is Right for You ?” March 8, 2018.
• Consideraciones de la Reforma Fiscal de los EUA para Inversionistas Extranjeros, enero de 2018.
•Co-author. “The U.S. Income Tax Treatment of Mexican Retirement Funds Owned by U.S. Persons,” Tax Management Compensation Planning Journal, Bloomberg BNA, November 3, 2017.
•“La Residencia Fiscal de las Personas Fisicas: Una Perspectiva Latinoamericana,” en Memorias del Premio Latinoamericano de Investigacion, Comite Regional Latinoamericano de la International Fiscal Association (IFA), Mayo de 2017.
• The IRS’s Current Offshore Voluntary Disclosure Program: Is This the Only Option Available for An ’Accidental American ?’ International Tax Journal, CCH Wolters Kluwer, January-February 2014.
•Contributing author. “Mexico’s Proposed Tax Reform: International and Cross border Highlights, October 2013.
•“Alternativas de Regularizacion ante el IRS,” IDC Asesor Fiscal, January 2013.
•‘Mexico.’ The ABA Guide to International Bar Admissions. Eds. Russell W. Dombrow and Nancy A. Matos. CITY: PUBLISHER, 2012.
•Co-author. “U.S. Tax Treaties and Section 6114: Why a Taxpayer’s Failure to ‘Take’ a Treaty Position Does Not Deny Treaty Benefits, ” CCH International Tax Journal, May-June 2011.
•Co-author. Overview of U.S. Interest Income, Exempt from U.S. Income Taxation for the Foreign Investor (‘Portfolio Interest’), February 2011.
•Co-author. Proposed Guidance: Why Mexican Retirement Funds Should Not Be Subject to the New Reporting Requirements Under IRC Section 1298(f), State Bar of California Taxation Section, International Committee, 2010.

Areas of Practice (4)

  • Tax, International
  • Mergers & Acquisitions and Strategic Joint Ventures
  • Tax, Corporate and Individual
  • Latin America - US Cross-Border

Education & Credentials

Contact Information:
619.515.3272  Phone
619.744.5457  Fax
University Attended:
Universidad Nacional Autónoma de México, Specialized Degree, International Trade Law, cum laude, 2006
Law School Attended:
Universidad Autónoma de Baja California - Campus Mexicali, LL.B., summa cum laude, 2004; Escuela Libre de Derecho, Diploma in Tax Law, 2005; University of Florida Levin College of Law, LL.M., International Taxation, 2009
Year of First Admission:
2010, California; Mexico


•Universidad Autonoma de Baja California - Adjunct Professor of Introduction to U.S. Tax Law
•American Bar Association - International and Tax Sections
•International Fiscal Association

Mexican Branch: Past Vice-Chair of YIN Committee
USA Branch: President of YIN Committee

•The State Bar of California - International and Tax Sections
•CalCPA - Co-Chair of International Tax Committee (San Diego)

Reported Cases:
Representative Matters: Advises clients on tax-efficient structures to implement cross-border mergers, acquisitions and joint ventures.; Counsels foreign companies and individuals looking to make investments and establish a presence in the U.S.; Assists U.S. companies and individuals to develop tax-efficient structures for their operations and investments abroad.; Advises on the acquisition and sale of Latin American companies owned by individuals in the U.S.; Represents clients in reviewing the potential impact of new U.S. tax laws in their international transactions.; Counsels foreign individuals planning to move into the U.S. in tax efficient manner, and U.S. individuals looking to renounce their U.S. citizenship.; Assists multinational families with ties to the U.S. to protect their assets and transfer wealth to future generations in a tax efficient manner.; Advises on tax implications of loans inv olving foreign persons and foreign beneficiaries.; Directs foreign clients to comply with their U.S. estate and gift tax obligations.; Assists U.S. and foreign clients to comply with their U.S. tax and reporting requirements with respect to their international operations and assets held in other countries.; Counsels in-house advisors of companies to set up compliance programs for their U.S. tax obligations.; Represents and advises foreign clients in audits and controversies with the U.S. tax authorities on tax treaty issues.

Peer Reviews

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*Peer Reviews provided before April 15, 2008 are not displayed.

Documents (4)

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San Diego, California

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