Michael C. Vandormael

Experience

• Conducted U.S. pre-immigration tax planning for non-resident aliens seeking temporary or permanent U.S. residency.
• Advised U.S. persons on the voluntary disclosure of undeclared foreign accounts, assets, and income.
• Advised foreign nationals on U.S. real estate investments and established various custom holding structures to minimize U.S. federal income and transfer taxes.
• Advised foreign nationals on debt and equity financing for U.S. investments projects.
• Advised U.S. and foreign persons on U.S. federal withholding and tax filing and reporting obligations.
• Advised U.S. beneficiaries on foreign trust taxation and reporting obligations (DNI, UNI, throwback rules, Form 3520, etc.).
• Advised U.S. citizens living abroad on various tax, estate planning and succession matters, including application of EU succession regulations (“Brussels IV Directives”).
• Advised U.S. persons on efficient tax planning of foreign operations, including analysis of CFC/PFIC regimes, FTC, check-the-box rules, and treaty based planning.
• Advised U.S. citizens and long term green card holders on expatriation procedures and “Exit Tax” minimization/avoidance.
• Advised foreign family business owners on expansion of their operations in the United States (business licensing, U.S. federal income/transfer tax, asset protection, and succession planning).
• Advised high net worth non-citizen spouse on U.S. income and transfer tax consequences of a property settlement agreement and the division of marital assets incident to divorce.
• Advised U.S. and foreign nationals on U.S. probate matters, including estate and trust administration.
• Provided estate planning advice to high net worth individuals, including planning for wealth transfer tax minimization, portability, probate avoidance, asset protection, incompetency, and guardianship planning, etc.
• Prepared estate planning documents, including, wills, trusts (CST, QTIP, QDOT, ILIT, IDGT, etc.), healthcare directives, powers of attorney, deeds, etc.
• Represented taxpayers in tax controversies before the IRS and Florida Department of Revenue relative to personal and corporate income tax returns, payroll returns, state reemployment and sales tax returns (OIC, IA, penalty abatements, collection, etc.)
• Advised tax exempt organizations of tax filing and reporting obligations, including the analysis of income producing activities subject to the unrelated business income tax.

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Credentials

Background

• Barbosa Legal (Miami Beach, FL)
  Associate (2016-2017)
• Global Tax and Estate Counsel, LLP (Miami)
  Associate (2014–2015)
• Vasallo Sloane, P.L. (Miami)
  Associate (2013)
• Global Tax and Estate Counsel, LLP (Miami)
  Associate (2012-2013)

Areas of Focus