
Holland & Knight LLP

About
Managing Partner: Steven Sonberg
Number of partners: 741
Number of lawyers: 1,344
Languages: Armenian, Bulgarian, Cantonese, Danish, English, Finnish, French, German, Greek, Guarani, Haitian Creole, Hebrew, Italian, Japanese, Korean, Mandarin, Norwegian, Persian (Farsi), Portuguese, Russian, Spanish, Swedish, Thai
Firm Overview:
Holland & Knight has one of the largest private wealth practices in the USA and assists ultra high net worth clients to attain and maintain their financial and wealth planning goals through sophisticated wealth transfer arrangements. Ultra high net worth individuals, private equity principals, substantial closely held and family businesses, family offices, charitable organisations, educational institutions, banks and trust companies are among its clients. The firm also handles a significant amount of complex probate, elder abuse and fiduciary misconduct litigation to trial and appeal. Purchases and sales of aircraft and yachts, art finance and virtual currency are among its services.
Main Areas of Practice:
Wealth Planning & Preservation:
33 partners, 40 other fee earners in the USA; one in Mexico
■ Comprehensive business succession, pre-liquidity planning, and estate planning services related to creation of a family office structure to provide centralised management of family business ventures for a family whose total assets exceed $1.5 Billion
■ Pre-immigration, estate and asset protection planning for international client who owns more than a dozen operating and holding companies throughout the world, significant US real property and art
■ Representing a family whose total assets exceed $1 Billion in comprehensive review of very successful thoroughbred horse operations and restructuring to transition ownership from the founder to a group of key employees
■ Representing an iconic entertainer in all business and personal endeavors. The private wealth team is responsible for asset structuring, tax and estate planning for the client and her husband
■ Advising clients through transitions of multi-generational family businesses, including succession planning, buyouts, reorganisations, corporate restructurings, and contentious changes of control
■ Developed and implemented a series of pre-IPO wealth transfer strategies involving the Founder’s stock. All of the transactions occurred prior to the company’s IPO filing and resulted in considerable intergenerational wealth transfer and exclusion of significant capital gains when the shares were sold as part of the IPO
■ Serve as Counsel to the Family Office of several professional sports teams owners
■ Unwinding longstanding LLC structure intended by the family office to streamline the administration of various trusts for the family as the most conservative response to several US tax cases concerning voting rights
■ Advising a US citizens residing abroad through a complex voluntary disclosures
Contact: David Scott Sloan
Tel: +1 617 573 5803
Email: [email protected]
Contact: Christopher Boyett
Tel: +1 305 789 7790
Email: [email protected]
Fiduciary Litigation:
28 partners, 14 other fee earners in the USA
■ Successfully represented Tyler Korff, grandson of former CBS and Viacom Chairman Sumner Redstone and the son of Shari Redstone, in multiple litigation matters across the US. The litigation concerned the future of the media mogul’s corporate empire and the eventual disposition of Mr. Redstone’s estate
■ Obtained a $4.9 million settlement in a breach of trust and elder financial abuse action against the former trustee over its management and oversight of the sale of the trust’s primary asset
■ Prosecuting two petitions against a successor trustee for the settlor’s breach of promise to make a will, provide inheritance, and breach of duty
■ Representing the sisters of a woman who went missing at sea and whose son is suspected of having murdered her and his grandfather. The case involves two jurisdictions, various trusts, a ‘slayer action’ to determine whether the son should forfeit his inheritance from his mother and grandfather, as well as related state estate tax audits
■ Representing the long-time wife in protracted disputes involving poorly drafted estate plans, conservatorship over ill husband’s person, facilitation of a neutral third-party conservator, detailed accounting, and dissolution of marriage
Contact: Vivian Thoreen
Tel: +1 213 896 2482
Email: [email protected]
Private Aircraft:
12 partners, 6 other fee earners in London, Miami, New York, San Francisco, Tysons, VA, and Washington, DC.
■ Representing numerous financial institutions in financing aircraft to international UHNW purchasers
■ Representing ultra UHNW purchaser and sellers and SPVs owned by UHNW clients in aircraft financing, acquisition and sale transactions
■ Advising a number of new entrants to private aircraft on acquisitions of fractional shares, jet cards and whole aircraft
■ Successfully represented several taxpayers in IRS audits regarding use of a corporate jets
Contact: Robert A Ricketts
Tel: +44 20 7071 9910
Email: [email protected]
Insurance:
4 partners in Portland, Miami and Boston
■ Outside counsel to several financial institutions on multiple multi-million dollar life insurance premium financing transactions
■ Advised multiple clients regarding how to navigate the termination of grandfathered split-dollar life insurance plans with tens of millions of dollars in policy cash value at stake
Contact: Joshua Husbands
Tel: +1 503 243 5862
Email: [email protected]
Ranked Offices
Provided by Holland & Knight LLP
- Brandon524 Grand Regency Blvd Suite 3300, , Brandon, Florida, USA, FL 33510
- Web: www.hklaw.com
- Tel: +1 305 374 8500
- Fax: +1 305 789 7799
- View ranked office
- Mexico CityPaseo de la Reforma No. 342 Piso 28, Col. Juárez, Del. Cuauhtémoc, Mexico City, Ciudad de México, Mexico, 06600View ranked office
- LondonLeaf 27C, Tower 42, 25 Old Broad Street, London, Greater London, UK, EC2N 1HQView ranked office
- Los Angeles400 South Hope Street, 8th Floor, Los Angeles, California, USA, CA 90071View ranked officePortland2300 US Bancorp Tower, 111 SW Fifth Avenue, Portland, Oregon, USA, OR 97204View ranked officeSan Francisco50 California Street, Suite 2800, San Francisco, California, USA, CA 94111View ranked officeStamfordOne Stamford Plaza, 263 Tresser Boulevard, Suite 1400, Stamford, Connecticut, USA, CT 06901-3271View ranked officeWashington, DC800 17th Street, NW, Suite 1100, Washington, DC, District of Columbia, USA, 20006View ranked office
Holland & Knight LLP rankings



















Articles, highlights and press releases
95 items provided by Holland & Knight LLP
Eighth Circuit Reversal in U.S. Virgin Islands Case Raises Important Statute of Limitation Concerns
The GILTI High-Tax Exception: Is it a Viable Planning Option?
The IRS issued the Global Intangible Low-Taxed Income (GILTI) high-tax exclusion final regulations on July 20, 2020.
IRS Releases Proposed Regulations on Carried Interest Under Section 1061 of the Code
The Internal Revenue Service on July 31, 2020, published proposed regulations (Proposed Regulations) on the tax treatment of certain partnership interests held in connection with the performance of services (such interests commonly referred to as carried interest).
Breaking the "Equity Wall": Proposed Regulations Limit Chances to Minimize U.S. Withholding Tax
This Holland & Knight alert presents a brief overview of the 30 percent withholding tax and the current "anti-conduit" rules, then describes the key changes that the Proposed Regulations would make.
The ABCs of Expatriation in These Chaotic Times
Expatriation has increased significantly in 2020. The latest U.S. Department of the Treasury Report reflects that a record 6,047 individuals expatriated during the first three quarters of 2020. In addition, 834,000 "green card" holders became U.S. citizens in FY 2019, which reflects an 11-year high.
Tax Court Upholds Application of Subpart F Manufacturing Branch Rule
The case is important not only because of its explication of the branch rule but also because it continuing application under current law, particularly with respect to the interaction of the Subpart F rules rules with the Global Intangible Low-Taxed Income (GILTI) provisions.
Business Tax Incentives and Relief Resulting from COVID-19 Response
As a result of the coronavirus (COVID-19) pandemic, several legislative and regulatory measures have been promulgated in an effort to assist businesses during the economic downturn. Below is a summary of the most important tax-related measures that are available to businesses.
Foreign Investment in Distressed Debt: Unique Tax Opportunities, But Beware of Pitfalls
This Holland & Knight alert discusses some key potential U.S. federal income tax opportunities and challenges for foreign investors in U.S. distressed debt.
IRS COVID-19 Extensions of Time Provide Relief to Taxpayers
The Internal Revenue Service (IRS) has provided taxpayers with needed relief by delaying the due dates with respect to various filings and payments during the coronavirus (COVID-19) pandemic. This alert summarizes the important aspects of recent IRS guidance, including Notice 2020-23.
The 2020 Stock Market Crash and PFIC Status
The recent drop in stock prices resulting from the coronavirus (COVID-19) pandemic has put certain foreign corporations at greater risk of being classified as "passive foreign investment companies" (PFICs). This alert provides a look at steps that can be taken to deal with the PFIC challenge.
Utilizing GRATs after a Market Downturn
Although drastic drops in the stock market can cause investor panic, they also present unique estate planning opportunities for gifting assets with reduced values. A particularly useful gifting vehicle in this economic environment is a GRAT.
U.S. Income Tax Residence and the Coronavirus
With the emergence COVID-19 pandemic, there are many non-U.S. individuals who will be spending significantly longer than expected in the United States this year. This alert addresses certain basic ground rules under current law for determining whether an individual is a U.S. income tax resident.
By 2021, it is likely that LIBOR will no longer exist, and even more likely that it will no longer be the leading global benchmark interest rate.
Corporate Jet Insurance and Liability Issues
An overview of insurance & liability issues for corporate jet owners, including elements of coverage, minimum liability limits, considerations when setting liability limits, premium cost, a case study & the possibility of transferring operational risk and liability to an aircraft management company
COVID-19: Executing Simple Agreements & Deeds Remotely Under English Law
Social distancing restrictions in place to combat the COVID-19 pandemic mean that the majority of people working in financial institutions, leasing companies, law firms and the corporate departments of airlines and other aircraft operators, among others, are working remotely from home.
Laura Lewis Named "Rising Star" by Airfinance Journal
Holland & Knight Attorney Laura Lewis has been selected as a 2020 "Rising Star" by Airfinance Journal. The trade publication identifies "Rising Stars" each year by asking readers around the globe to nominate promising young attorneys whom they feel best serve the aviation industry.
Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses
The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime, including many reforms that focus on multinational corporations. However, some lesser known TCJA provisions apply to foreign individuals.
Tax Planning is Critical for Colombians Moving to the United States
Seth Entin explains that pre-immigration U. S. tax planning is critical for a high-net-worth Colombian who is considering moving to the United States. Mr. Entin shares that any pre-immigration plan will have to be designed and implemented with great care.
Goodbye to the Parking Tax! IRS Authorizes Refunds for Exempt Organizations
After the Tax Cuts and Jobs Act of 2017 (P.L. 115-97) added Section 512(a)(7) to the Internal Revenue Code (IRC), the tax imposed by that section quickly became known as the "parking tax." This provision required every tax-exempt organization to increase its unrelated business taxable income
The No-Existence Theory and Pre-Immigration Check-the-Box Planning
Significant U.S. federal income tax planning is often recommended for a nonresident alien individual who plans to become a U.S. citizen or resident for U.S. federal income tax purposes (referred to as a U.S. person).
Wealth Succession Planning for Chinese Families
Without proper planning, many high-net-worth Chinese families may struggle to retain their wealth and maintain family harmony across multiple generations. This article addresses how to provide a grantor and his or her family the tools to develop a bespoke family governance structure.
New California Legislation for Trust and Estate Attorneys to Watch in 2020
New California laws, effective Jan. 1, 2020, include an increase in the maximum allowable amount for small-estate affidavits, the inclusion of broker-dealers and investment advisors as mandated reporters for elder abuse, and the elimination of a caretaker "loophole."
SECURE Act: Rethinking Estate Planning with Retirement Accounts
The Setting Every Community Up for Retirement Enhancement Act (the SECURE Act) represents the first major retirement legislation since 2006. The SECURE Act was signed into law on Dec. 20, 2019, became effective Jan. 1, 2020
Virtual Currency: The Taxman is Coming
Virtual currency transactions are coming under intense scrutiny by the Internal Revenue Service (IRS).As a result, U.S. persons who have engaged in virtual currency transactions and failed to properly report or pay tax on these transactions should become U.S. tax compliant or face serious civil or
Thoughtful Estate Planning – Is It Really Necessary?
The short answer is yes, but it’s not a straight path to the goal. The modern family structure continues to evolve from the Leave It To Beaver days to a more complex version of the Brady Bunch, with blended families.
Sour Grapes: When Decanting Gives Rise to Litigation
By the end of 2018, there were 29 states that had enacted trust decanting statutes, with approximately 22 of those taking effect in the last decade. With the prevalence of decanting increasing, courts are increasingly being forced to consider the circumstances under which decanting is permissible.
Is the New IRS Expatriation Initiative Really Better than an Existing Program and Law?
On September 6, 2019, the IRS introduced an enhanced, streamlined program for certain U.S. citizens who have relinquished their U.S. citizenship or will do so in the future.
E-Filing Now Mandatory for All Exempt Organizations
The Taxpayer First Act, which was signed into law by President Donald Trump on July 1, 2019, changed the requirements for tax-exempt organizations to require electronic filing of all returns in the Form 990 series and Form 8872.
Wealth Succession Planning for Chinese Families
Without proper planning, many high-net-worth Chinese families may struggle to retain their wealth and maintain family harmony across multiple generations.
Sour Grapes: When Decanting Gives Rise to Litigation
As decanting litigation continues to develop, there are common themes and potential issues that could arise in the future. Courts, trustees and trusts and estates practitioners should familiarize themselves with the current trends of decanting statutes.
Eighth Circuit Reversal in U.S. Virgin Islands Case Raises Important Statute of Limitation Concerns
The GILTI High-Tax Exception: Is it a Viable Planning Option?
The IRS issued the Global Intangible Low-Taxed Income (GILTI) high-tax exclusion final regulations on July 20, 2020.
IRS Releases Proposed Regulations on Carried Interest Under Section 1061 of the Code
The Internal Revenue Service on July 31, 2020, published proposed regulations (Proposed Regulations) on the tax treatment of certain partnership interests held in connection with the performance of services (such interests commonly referred to as carried interest).
Breaking the "Equity Wall": Proposed Regulations Limit Chances to Minimize U.S. Withholding Tax
This Holland & Knight alert presents a brief overview of the 30 percent withholding tax and the current "anti-conduit" rules, then describes the key changes that the Proposed Regulations would make.
The ABCs of Expatriation in These Chaotic Times
Expatriation has increased significantly in 2020. The latest U.S. Department of the Treasury Report reflects that a record 6,047 individuals expatriated during the first three quarters of 2020. In addition, 834,000 "green card" holders became U.S. citizens in FY 2019, which reflects an 11-year high.
Tax Court Upholds Application of Subpart F Manufacturing Branch Rule
The case is important not only because of its explication of the branch rule but also because it continuing application under current law, particularly with respect to the interaction of the Subpart F rules rules with the Global Intangible Low-Taxed Income (GILTI) provisions.
Business Tax Incentives and Relief Resulting from COVID-19 Response
As a result of the coronavirus (COVID-19) pandemic, several legislative and regulatory measures have been promulgated in an effort to assist businesses during the economic downturn. Below is a summary of the most important tax-related measures that are available to businesses.
Foreign Investment in Distressed Debt: Unique Tax Opportunities, But Beware of Pitfalls
This Holland & Knight alert discusses some key potential U.S. federal income tax opportunities and challenges for foreign investors in U.S. distressed debt.
IRS COVID-19 Extensions of Time Provide Relief to Taxpayers
The Internal Revenue Service (IRS) has provided taxpayers with needed relief by delaying the due dates with respect to various filings and payments during the coronavirus (COVID-19) pandemic. This alert summarizes the important aspects of recent IRS guidance, including Notice 2020-23.
The 2020 Stock Market Crash and PFIC Status
The recent drop in stock prices resulting from the coronavirus (COVID-19) pandemic has put certain foreign corporations at greater risk of being classified as "passive foreign investment companies" (PFICs). This alert provides a look at steps that can be taken to deal with the PFIC challenge.
Utilizing GRATs after a Market Downturn
Although drastic drops in the stock market can cause investor panic, they also present unique estate planning opportunities for gifting assets with reduced values. A particularly useful gifting vehicle in this economic environment is a GRAT.
U.S. Income Tax Residence and the Coronavirus
With the emergence COVID-19 pandemic, there are many non-U.S. individuals who will be spending significantly longer than expected in the United States this year. This alert addresses certain basic ground rules under current law for determining whether an individual is a U.S. income tax resident.
By 2021, it is likely that LIBOR will no longer exist, and even more likely that it will no longer be the leading global benchmark interest rate.
Corporate Jet Insurance and Liability Issues
An overview of insurance & liability issues for corporate jet owners, including elements of coverage, minimum liability limits, considerations when setting liability limits, premium cost, a case study & the possibility of transferring operational risk and liability to an aircraft management company
COVID-19: Executing Simple Agreements & Deeds Remotely Under English Law
Social distancing restrictions in place to combat the COVID-19 pandemic mean that the majority of people working in financial institutions, leasing companies, law firms and the corporate departments of airlines and other aircraft operators, among others, are working remotely from home.
Laura Lewis Named "Rising Star" by Airfinance Journal
Holland & Knight Attorney Laura Lewis has been selected as a 2020 "Rising Star" by Airfinance Journal. The trade publication identifies "Rising Stars" each year by asking readers around the globe to nominate promising young attorneys whom they feel best serve the aviation industry.
Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses
The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime, including many reforms that focus on multinational corporations. However, some lesser known TCJA provisions apply to foreign individuals.
Tax Planning is Critical for Colombians Moving to the United States
Seth Entin explains that pre-immigration U. S. tax planning is critical for a high-net-worth Colombian who is considering moving to the United States. Mr. Entin shares that any pre-immigration plan will have to be designed and implemented with great care.
Goodbye to the Parking Tax! IRS Authorizes Refunds for Exempt Organizations
After the Tax Cuts and Jobs Act of 2017 (P.L. 115-97) added Section 512(a)(7) to the Internal Revenue Code (IRC), the tax imposed by that section quickly became known as the "parking tax." This provision required every tax-exempt organization to increase its unrelated business taxable income
The No-Existence Theory and Pre-Immigration Check-the-Box Planning
Significant U.S. federal income tax planning is often recommended for a nonresident alien individual who plans to become a U.S. citizen or resident for U.S. federal income tax purposes (referred to as a U.S. person).
Wealth Succession Planning for Chinese Families
Without proper planning, many high-net-worth Chinese families may struggle to retain their wealth and maintain family harmony across multiple generations. This article addresses how to provide a grantor and his or her family the tools to develop a bespoke family governance structure.
New California Legislation for Trust and Estate Attorneys to Watch in 2020
New California laws, effective Jan. 1, 2020, include an increase in the maximum allowable amount for small-estate affidavits, the inclusion of broker-dealers and investment advisors as mandated reporters for elder abuse, and the elimination of a caretaker "loophole."
SECURE Act: Rethinking Estate Planning with Retirement Accounts
The Setting Every Community Up for Retirement Enhancement Act (the SECURE Act) represents the first major retirement legislation since 2006. The SECURE Act was signed into law on Dec. 20, 2019, became effective Jan. 1, 2020
Virtual Currency: The Taxman is Coming
Virtual currency transactions are coming under intense scrutiny by the Internal Revenue Service (IRS).As a result, U.S. persons who have engaged in virtual currency transactions and failed to properly report or pay tax on these transactions should become U.S. tax compliant or face serious civil or
Thoughtful Estate Planning – Is It Really Necessary?
The short answer is yes, but it’s not a straight path to the goal. The modern family structure continues to evolve from the Leave It To Beaver days to a more complex version of the Brady Bunch, with blended families.
Sour Grapes: When Decanting Gives Rise to Litigation
By the end of 2018, there were 29 states that had enacted trust decanting statutes, with approximately 22 of those taking effect in the last decade. With the prevalence of decanting increasing, courts are increasingly being forced to consider the circumstances under which decanting is permissible.
Is the New IRS Expatriation Initiative Really Better than an Existing Program and Law?
On September 6, 2019, the IRS introduced an enhanced, streamlined program for certain U.S. citizens who have relinquished their U.S. citizenship or will do so in the future.
E-Filing Now Mandatory for All Exempt Organizations
The Taxpayer First Act, which was signed into law by President Donald Trump on July 1, 2019, changed the requirements for tax-exempt organizations to require electronic filing of all returns in the Form 990 series and Form 8872.
Wealth Succession Planning for Chinese Families
Without proper planning, many high-net-worth Chinese families may struggle to retain their wealth and maintain family harmony across multiple generations.
Sour Grapes: When Decanting Gives Rise to Litigation
As decanting litigation continues to develop, there are common themes and potential issues that could arise in the future. Courts, trustees and trusts and estates practitioners should familiarize themselves with the current trends of decanting statutes.