Guillermo Fernández-Quincoces - Director

Steel Hector & Davis, LLP
Partner
200 South Biscayne Boulevard
Miami, FL 33131-2398
Phone: (305) 577-7018  Fax: (305) 577-7001      
E-mail: gfernandez-quincoces@steelhector.com

Practice Areas

• Corporate

• International

• Tax - General Tax and Estate and Gift

Experience

• PriceWaterhouseCoopers (At that time, Price Waterhouse & Co), Staff Auditor

• Deloitte and Touche (At that time Deloitte Haskins & Sells), Sr. Manager, Tax Department, New York Practice Office and National Tax Department.

• Fine, Jacobson, Schwartz, Nash & Block, P.A.; Partner, Tax Department

• Gunster, Yoakley, Valdes-Fauli & Stewart, P.A.; (now Gunster Yoakley) Partner, Tax Dept.

• University of Miami, Graduate School of Business, Instructor in Taxation (Corporate taxation, Taxation of Nonresident Aliens and Foreign Corporations, Estate & Gift Taxation, Income Taxation of Trusts and Estates), Instructor in Accounting (Financial and Managerial Accounting)

• Member of the Board of Directors, Bacardi, Ltd. 2001-2004

• Served in various committees of the Board (Compensation, Audit, and Shareholder Issues).

Representative Transactions

• Representation of 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.

• Preparation of trusts holding on-shore and off-shore assets, closely held business interests, and life insurance.

• Representation of 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.

• International and general tax law (inbound and outbound U.S. tax planning), commercial law, international cross border transactions, and representation of purchasers in privatizations.

• Representation of Fortune 100 companies (in the foodstuffs and leisure industry) 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.

• Establishment of 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.

• Establishment of complex Dutch, and U.K. based structures for both international clients and U.S. companies seeking treaty benefits, have prepared and obtained favorable private letter rulings on “Portfolio Debt” issues.

• Acted as the lead attorney in a nine figure merger between a number of companies which were privately held by one client, and a publicly listed REIT.

• Working knowledge of aspects of the Civil Law in various South American countries.

• Have acted as tax and general counsel for a local cigarette manufacturer and its majority stockholder.

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Education Boston University, J.D., 1977 Harvard University, M.B.A., 1974 St. Peter's College, B.S., 1970

Bar & Court Admissions Florida, 1979 U.S. Tax Court, 1979

 Professional Involvement

• The Florida Bar, 1979

• Member, International Tax Committee, 1984-present

• Admitted to practice - U.S. Tax Court, 1979

• Certified Public Accountant, New York, 1977

• American Bar Association

• Taxation Section

• Income taxation of Trusts & Estates

• Dade County Bar Association

• Cuban American Bar Association, Director

• Sixth Conference of the Lawyers of the Americas, 1988, responsible for coordinating all presentations for the conferences (one full day of tax related topics) held in 1980, 1982, 1984, 1986, 1990, and 1992. The conferences were held in the Spanish language.

• Florida Institute of Certified Public Accountants

• Organizer and speaker, Estate Planning Conference 1985, 1986, 1996-2002

• Member, Dade Chapter FICPA Board of Directors 1995-1999

• Committee on Financial Planning and Multi Disciplinary Practices, 2000-03

• Cuban American Certified Public Accountants Association,  Board of Directors, 1988, 1990, 1992,1998, 2000 - 2003

• President, 1993-94, President elect 1992-1993

• Greater Miami Chamber of Commerce

• Hispanic Affairs Committee

• Spain/U.S. Chamber of Commerce,

• Drafter of the Chamber’s organizational documents

• Board of Directors, 1989 and 1990

• Florida Association of Attorney-Certified Public Accountants

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Community Involvement

• Planned Giving Council of Dade County

• Legal Services of Greater Miami, Inc.

• Dade Community Foundation - Member, Board of Directors, 1996-present

• Cuban American Bar Association Pro-Bono Services

Honors

• AV Rated by Martindale Hubbell

Speeches and Presentations

• Representative List:

• Choice of Entity: The Use of LLPs, LLCs, General and Limited Partnerships, Corporations and ‘S’ Corporations”

• “Pre-Immigration Planning; Legal and Tax Issues”

• “The Limited Liability Company”

• “Partnership Taxation Issues:  FLPs and LLCs”

• “Basic Partnership Taxation Issues Related To The Creation, Operation And Termination Of Family Limited Partnerships”

• “Doing Business In The U.S.: Income, Gift, and Estate Tax Planning for Non-resident Aliens

• Advanced Estate Planning Topics”

• “Recent Developments:  Family Limited Partnerships and Family Limited Liability Companies Tax Cases”

• “Economic Growth and Tax Relief Reconciliation Act of 2001”

• “Cinderella and Other Fairy Tales: The 2001 Tax Act”

• “U.S. Taxation of Foreign Investments by U.S. Taxpayers and Residents: CFCs, FPHCs & PFICs"

• “Objectives Of Estate Planning”

• “Investing Abroad: Host Country Tax Considerations”

• “Esoteric Estate Planning Topics”

• “Divulgación Equitativa (Fair Disclosure Regulations under Regulation FD) (In Mexico)

• “Tax Comparison: LLCs vs. Corporation And Partnerships”

• “Direct Skip Tax Computations: The Generation Skipping Tax”

• “The Foreign Corrupt Practices Act”

• “Dynasty Trusts, Family Limited Partnerships And Domestication Of A Foreign Trust: A Fiduciary’s Road Map”

• “Basic Probate”

• “Long Term Incentive Plans; Tax and Legal Issues”

• “The Use of LLCs in a Foreign Context”

• “The Tax System of the United States” In Spanish

• “Basic Estate Planning”

• “Consecuencias Impositivas de las Inversiones cn Compañías Extranjeras por Ciudadanos   Estadounidenses, Residentes Fiscales y Entidades Domésticas”

• “Selecting a Tax Haven”

• “A Primer on Offshore Trusts”

• “Reporting Requirements of Investment in Offshore Companies and Receipts from Foreign Trusts”

• “Overview Of The Check-The-Box Regulations”

• “United States Transfer Taxation (Estate, Gift, And Generation Skipping Tax) Of Foreign    Persons”

• “United States Income Taxation Of Foreign Persons”

• “Application of the Civil Law in Florida: The Double Step of Basis under Section 1014(b)(6)”

• “The Florida Elective Share Statute”

• “The U.S./Spain Income Tax Treaty” - In Spanish to the Madrid Bar Association

• “PLR 9110019 - An Accident Waiting for a Place to Happen In The Use of Revocable Trusts by Non-U.S. Persons Married to U.S. Citizens”

• “Life Insurance Trusts: What they are and how they work”

• “The Use of Trusts in Estate Planning: Advanced Topics”

Languages

• Spanish (fluent both in colloquial and technical Spanish), able to draft documents, negotiate, and translate U.S. legal terms into Spanish and vice versa.