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Larry R. Kemm

Larry R. Kemm

Of Counsel

Overview

Larry Kemm’s practice focuses on international tax matters for both domestic and non-U.S. clients. With 30 years of combined practice as a tax lawyer and CPA, Larry has vast experience advising clients in structuring international transactions and business operations in a tax efficient manner, and in representing clients before the IRS in international tax disputes.

Larry counsels clients on international tax matters related to the organization and reorganization of cross-border business structures, including international joint ventures, mergers, acquisitions and divestitures. In addition, he advises clients on international tax planning matters, such as income tax deferral, foreign tax credit utilization, transfer pricing strategies and maximization of tax treaty benefits, among others. He coordinates global planning and transaction structures by working with an extensive network of lawyers throughout the world.

Larry has served as counsel in numerous tax controversy matters at the audit, appeals and litigation levels. He has also represented numerous clients in voluntary disclosures, as well as penalty disputes related to foreign bank account reporting under the Bank Secrecy Act.

Larry speaks regularly before various professional organizations and has authored numerous publications on international tax topics. He is licensed as a Certified Public Accountant in the State of Texas, and is admitted to practice before the United States Tax Court, the United States Court of Federal Claims and the United States District Court for the Northern District of Texas.

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Recognition

  • AV Rated by Martindale-Hubbell
  • Listed in The Best Lawyers in America, Tax Law (2013-2019)

Professional & Community Involvement

  • Licensed Certified Public Accountant in the State of Texas
  • The Florida Bar
    •  International Tax Committee of the Tax Section
  • American Bar Association
    • Section of Taxation
  • Hillsborough County Bar Association
    • Tax Law Section 
  • Member, International Fiscal Association
  • Member, Society of International Business Fellows
  • Society of Trust and Estate Practitioners (STEP)

Speaking Engagements

  • “Tax Controversies and Multinational Enterprises,” Tax Executives Institute Florida Chapter Conference (May 2017)
  • “Offshore Tax Compliance Issues (from a Tax Controversy Perspective)” The Frances D. Sheehy Memorial Advanced Tax Procedure Seminar, Florida Bar Tax Section (May 2017)
  • “International Tax Update,” STEP – Los Angeles Chapter (March 2017)
  • “Current Developments in International Taxation – Outbound Update,” 35th Annual International Tax Conference, Florida Bar Tax Section and FICPA (January 2017)
  • “Recent Developments in the Intersection Between Federal Tax Law and the Administrative Procedure Act,” Florida Bar Tax Section (May 2016)
  • “Current Developments in International Taxation – Outbound Update,” 34th Annual International Tax Conference, Florida Bar Tax Section and FICPA (January 2016)
  • “Current Developments in International Taxation – Outbound Update,” 33th Annual International Tax Conference, Florida Bar Tax Section and FICPA (January 2015)
  • “Current Developments in International Taxation – Outbound Update,” 32nd Annual International Tax Conference, Florida Bar Tax Section and FICPA (January 2014)
  • “U.S. International Tax Legislative/Regulatory Forecast and Update,” Institut für Schweizerisches und Internationales Steuerrecht, Zurich (May 2013)
  • “Current Developments in International Taxation – Outbound Update,” 31st Annual International Tax Conference, Florida Bar Tax Section and FICPA (January 2013)
  • “U.S. Tax Compliance Issues Facing Trustees, Settlors and Beneficiaries of Foreign Trusts,” Zurich (October 2012)
  • “Current Developments in International Taxation – Outbound Update,” 30th Annual International Tax Conference, Florida Bar Tax Section and FICPA (January 2012)
  • “Contract Manufacturing in China,” Hillsborough County Bar Association Tax Section (May 2008)
  • “Computing the Gain from the Sale of CFC Shares Under Section 1248,” Council for International Tax Education, Chicago (June 2007)
  • “Computing the Gain from the Sale of CFC Shares Under Section 1248,” Council for International Tax Education, St. Louis (April 2007)
  • “Foreign Tax Credit Planning,” Tax Executives Institute (Chicago Chapter), International Tax Forum (September 2006)
  • “The Use of Partnerships in International Tax,” McDermott Corporate and International Tax Forum (September 2005)
  • “Taxable Sale of CFC Stock,” Council for International Tax Education (April 2005)
  • “Recent Changes in Intercompany Debt Financing ‘Thin Capitalization’ Rules & Related Planning Strategies,” The Chicago Tax Club (October 2004)
  • “How the Subpart F Anti-Deferral Rules Operate,” Council for International Tax Education (November 2003)
  • “Controlled Foreign Corporations – Deferral Planning,” Alliance for Tax, Legal and Accounting Seminars (August 2003)
  • “Current Developments and Proposed Reforms in International Tax,” Tax Executives Institute (October 2002)
  • “Inversion Transactions: A Nuts and Bolts Approach,” The Chicago Tax Club (April 2002)

Credentials

Education
  • Indiana University Robert H. McKinney School of Law (J.D., summa cum laude, 1992)
  • University of Missouri at Kansas City (B.S., Accounting, 1984)
Bar Admissions
  • Florida
  • Illinois
  • Texas
Court Admissions
  • U.S. Court of Federal Claims
  • U.S. District Court, Northern District of Texas
  • U.S. District Court, Western District of Texas
  • U.S. Tax Court

Background

  • Partner, Harrison Kemm P.A., Tampa, FL (2013-2016)
  • Partner, Sharp Kemm P.A., Tampa, FL (2007-2013)
  • Partner, McDermott Will & Emery, Chicago (2003-2007) 
  • Partner, Baker & McKenzie (2000-2003)
  • Associate, Baker & McKenzie (1994-2000)
  • Certified Public Accountant, Deloitte

Disclaimer

The information on this website is presented as a service for our clients and Internet users and is not intended to be legal advice, nor should you consider it as such. Although we welcome your inquiries, please keep in mind that merely contacting us will not establish an attorney-client relationship between us. Consequently, you should not convey any confidential information to us until a formal attorney-client relationship has been established. Please remember that electronic correspondence on the internet is not secure and that you should not include sensitive or confidential information in messages. With that in mind, we look forward to hearing from you.