Procopio, Cory, Hargreaves & Savitch : Attorneys : Patrick Martin

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Patrick W. Martin Partner

Practice Areas	Admissions
International Law Tax	California District of Columbia Foreign Language(s) Spanish

Contact Information

530 B Street, 21st Floor San Diego, CA 92101 Direct Phone: 619.515.3230 Direct Fax: 619.744.5430 pwm@procopio.com v-Card Download Bio

Professional Summary

Mr. Martin is a member of the Firm’s Management Committee, the firm's Tax Practice Group, and leader of the firm's International Practice Group. His practice emphasizes international tax planning and related international law matters. He represents foreign individuals, multi-national families, companies, international athletes, entertainers and entertainment groups in such areas as developing worldwide investment and financing structures, international tax treaty planning strategies and planning worldwide income, estate and inheritance taxes. He helps resolve and plan for international tax controversies and develops international wealth preservation structures to compliment the client’s international investments and business transactions with a particular emphasis on Mexican and Latin American real estate transactions.

Representative Matters

Assist numerous U.S. developers (land and construction development) with Mexican and Latin America (e.g., Costa Rica and Guatemala) real estate acquisitions and development (structuring global operations, financing, equity investment, repatriation of funds and tax treaty benefits)

Advise regarding international real estate development projects in Asia

Advise U.S. developers regarding complex Mexican land related litigation issues with Mexican litigation counsel

Advise U.S. and international investment funds regarding tax preferred structures for joint U.S.-Latin American land investment, private equity investment, cross border financing and repatriation of real estate profits

Advise various Central American real estate and land and real estate developers on global international tax structuring related to timing of sales, investment and tax preferred structures

Assist multiple Latin American real estate clients regarding private equity investment, financed sales and joint ventures with U.S. and Latin American individual and institutional investors

Assist various multi-million dollar Mexican real estate land owners with U.S. joint venture real estate developments

Represents various multi-national families in developing worldwide income, estate and inheritance tax and international wealth preservation structures including advising and defending audits by tax authorities

Represents various Mexican, Latin American, Asian, South Pacific and European manufacturing, technology and agricultural companies with U.S. and worldwide joint venture, distribution and sales companies

Represents international entertainers (including various Grammy Award winners) regarding tax planning considerations of their worldwide publishing, promotion, concerts, tax-exempt foundations, sales, and related activities

Represents several international income and estate tax audits before the IRS, including representation before the U.S. Tax Court

Represents various foreign families and individuals regarding pre-immigration and pre-expatriation planning to avoid and/or limit U.S. income, estate and gift tax consequences prior to: (a) immigrating into and taking up tax residency or domicile in the U.S., or (b) expatriating from the U.S.

Education, Distinctions & Community Involvement

Mr. Martin received his law degree from the University of San Diego School of Law in 1992 where he was a Thomas More scholar, and also studied international law (Régimen Jurídico de Los Negocios Internacionales en México) at the celebrated Mexican law school, La Escuela Libre de Derecho in Mexico City. He was a summer associate with the IRS District Counsel (Treasury Dept.).

Mr. Martin is the past chair of the International committee, Taxation Section of the State Bar of California. He is a former chairman and current member of the San Diego County Bar Taxation Section, a member of the International Law Section of the State Bar of California, a past member of the Executive Committee of the Taxation Section of the State Bar of California, and a member of the American Bar Association. He is also licensed to practice in Washington, D.C. and is a member of the International Tax Planning Association, International Fiscal Association, and the U.S. Tax Court. Mr. Martin is a member of the Advisory Board of Fondo Para La Paz and the Alumni Board of the University of San Diego School of Law. He also provides pro bono legal counsel to Selva Negra.

Mr. Martin is AV rated attorney by Martindale-Hubbell and was selected for inclusion in the 2007 and 2008 Southern California Super Lawyers® - San Diego list in the Tax category.

News*, Publications & Events

Mr. Martin is frequently asked to speak at international tax and law conferences. He has also written extensively on matters of international tax law and a list of published articles can be provided upon request.