Holland & Knight LLP
USA Guide 2023
Holland & Knight LLP
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About
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
- Miami701 Brickell Avenue Suite 3300 , Miami, Florida, USA, FL 33131
- Web: www.hklaw.com
- View ranked office
- Atlanta1180 West Peachtree Street, One Atlantic Center, Suite 1800, Atlanta, Georgia, USA, GA 30309View ranked officeFort Lauderdale515 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida, USA, FL 33301View ranked officeJacksonville50 North Laura Street, Suite 3900, Jacksonville, Florida, USA, FL 32202View ranked officeLos Angeles400 South Hope Street, 8th Floor, Los Angeles, California, USA, CA 90071View ranked officeNashvilleNashville City Center 511 Union Street Suite 2700 , Nashville, Tennessee, USA, TN 37219View ranked officePhiladelphia2929 Arch Street, Suite 800, Philadelphia, Pennsylvania, USA, PA 19104View ranked officeStamfordOne Stamford Plaza, 263 Tresser Boulevard, Suite 1400, Stamford, Connecticut, USA, CT 06901-3271View ranked officeTallahassee315 South Calhoun Street, Suite 600, Tallahassee, Florida, USA, FL 32301View ranked officeTysons Corner1650 Tysons Boulevard, Suite 1700, Tysons Corner, Virginia, USA, VA 22102View ranked officeWashington, DC800 17th Street, NW, Suite 1100, Washington, DC, District of Columbia, USA, 20006View ranked officeWest Palm Beach777 South Flagler Drive Suite 1900, West Tower , West Palm Beach, Florida, USA, FL 33401View ranked office
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Articles, highlights and press releases
246 items provided by Holland & Knight LLP
Biden Administration's Made in America Tax Plan: Procedural Aspects
Part 1: Buckle Up for the Impact on International Tax Reform
Contract Allocations and Judicial Doctrines
District Court Case Applies Strong Proof Test to Boxing Contracts to Address Puerto Rico Source Income
Biden Administration's Made in America Tax Plan: Interaction with OECD Inclusive Framework
Part 2: Buckle Up for the Impact on International Tax Reform
IRS Continues to Audit and Litigate Against Cannabis Businesses
As Congress continues to deliberate the federal legalization of marijuana, the cannabis industry continues to face scrutiny from the IRS under Section 280E of the Internal Revenue Code (Code).
Tax Liability Issues to Consider for High-Net-Worth Couples in Divorce
Divorce is not a topic most clients or tax advisors enjoy discussing.
Biden's American Families Plan Proposes Income Tax Hikes
The American Families Plan is the third part of the Biden Administration's Build Back Better agenda, addressing "human infrastructure" and containing proposals on free education, direct support to children and families, and the extension of tax cuts for families with children and American workers.
Large Corporations and Wealthy Taxpayers Beware: The Taxman is Coming
Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap1 in the U.S. may total $1 trillion per year.
Tennessee retains status as a leading trust jurisdiction
On May 12, 2021, Tennessee Governor Bill Lee signed into law a bill containing several revisions to Tennessee’s Uniform Trust Code (the “TN UTC”).
When IRS Penalty Assertions Are Unlawful
One of the most highly litigated issues in U.S. Tax Court is whether taxpayers are liable for certain penalties, additions to tax or additional amounts (each, a "penalty" and collectively, "penalties").
U.S. Supreme Court Decision May Pave Way for Future IRS Lawsuits
The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the Internal Revenue Service (IRS), delivering an important victory to CIC and similarly situated taxpayers everywhere.
Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy
By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government.
Biden Administration's FY 2022 Budget and International Tax Changes
A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy," June 3, 2021.)
The Green Book and Green Energy
Biden Administration's Budget Proposal Expands, Extends and Creates Tax Credits for Renewable Energy
Agreement on Global Tax Reform: What Happened and What's Next
Addressing the tax challenges arising from the digitalization of the economy has been a top priority of the Base Erosion Profit Shifting (BEPS) project of the Organization for Economic Cooperation and Development (OECD)/G-20 Inclusive Framework (IF)1 since 2015.
How Can the Same Right Create 2 Separate Property Interests?
A Closer Look at Taxpayers' Property Rights, State Laws and the Legitimacy of IRS Liens/Levies
IRS Promotes Use of Fallback Language to Assist with Libor, IBOR Transition
The Internal Revenue Service (IRS) released Revenue Procedure 2020-44 to assist the market's transition from the London Interbank Offered Rate (Libor) and other interbank offered rates (IBORs) to alternative reference rates by promoting the adoption of fallback language recommended by the...
U.K., U.S. Reach Competent Authority Agreement on "Equivalent Beneficiary" Status
The United Kingdom and the U.S. Competent Authorities published on July 28, 2021, a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty).1
Offshore Lenders Targeted by IRS Audit Campaign
Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations, premised on strategically identified and prioritized areas of compliance risks to address taxpayer compliance.
IRS Extends Time Period of Telephonic Public Approval Hearings for Private Activity Bonds
The Internal Revenue Service (IRS) has released Revenue Procedure 2021-39, which extends the time period for telephonic Tax Equity and Fiscal Responsibility Act (TEFRA) hearings until March 31, 2022.
IRS Adds a Potential Self-Dealing Transaction to the No-Rule List
The IRS issued Revenue Procedure 2021-40, 2021-38 IRB 1 on Sept. 3, 2021, adding a private foundation issue to the list of those areas on which the IRS will no longer issue private letter rulings or determination letters: The IRS indicated that it is "currently reviewing" its prior ruling position..
Regulatory Changes Impact Leasehold Condominiums in New York
The leasehold condominium structure has become a popular way for landlords and nonprofit entities to establish or modify their relationship to permit space that the nonprofit would formerly lease to qualify for a real property tax exemption.
Regulatory Changes Impact Leasehold Condominiums in New York
The leasehold condominium structure has become a popular way for landlords and nonprofit entities to establish or modify their relationship to permit space that the nonprofit would formerly lease to qualify for a real property tax exemption.
NBAA Article Explains IRS Stance on Entertainment Disallowance for Sole Proprietors
The Internal Revenue Service (IRS) recently released Chief Counsel Advice (CCA) 2021-17-012 to explain that sole proprietor flights are generally not subject to the employer-provided aircraft rules in Internal Revenue Code Section 274
House Ways and Means Committee Tax Plan Proposes Changes to Estate Planning
The House Committee on Ways and Means has proposed a tax plan intended to fund President Joe Biden's "Build Back Better" $3.5 trillion infrastructure program.
Maintaining Privilege with Non-Lawyer Experts Under Kovel
Holland & Knight Partners Abbey Garber and Denise Mudigere, along with Associate Kate Minnich, co-authored an article in the December 2021 issue of Headnotes, a publication of the Dallas Bar Association.
Update for Employers: Recent Legislation Improves, Extends Employee Retention Credit
The Coronavirus Aid, Relief, and Economic Security (CARES) Act authorized a refundable tax credit important to many employers struggling as a result of the COVID-19 pandemic.
Same Statute, Same Form, Different Penalties: Welcome to FBAR Litigation
The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation.
Increased Hart-Scott-Rodino Thresholds Set to Take Effect Feb. 23, 2022
The Federal Trade Commission (FTC) has announced this year's revisions to the thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (HSR), which will apply to all transactions closing on or after Feb. 23, 2022.
IRS Issues Favorable Tax Regulations on Management Company Exception to FET
Over the past few years, the Internal Revenue Service (IRS) has worked to issue final regulations that provide guidance to aircraft management companies and aircraft owners regarding their federal excise tax (FET) obligations.
Proposed Regulations Greatly Expand Guidance on Required Minimum Distributions
The Internal Revenue Service (IRS) issued expansive proposed regulations (the Proposed Regulations) on Feb. 24, 2022, reflecting the required minimum distribution (RMD) rules as set out in the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019 and providing significant...
Biden Administration's Made in America Tax Plan: Procedural Aspects
Part 1: Buckle Up for the Impact on International Tax Reform
Contract Allocations and Judicial Doctrines
District Court Case Applies Strong Proof Test to Boxing Contracts to Address Puerto Rico Source Income
Biden Administration's Made in America Tax Plan: Interaction with OECD Inclusive Framework
Part 2: Buckle Up for the Impact on International Tax Reform
IRS Continues to Audit and Litigate Against Cannabis Businesses
As Congress continues to deliberate the federal legalization of marijuana, the cannabis industry continues to face scrutiny from the IRS under Section 280E of the Internal Revenue Code (Code).
Tax Liability Issues to Consider for High-Net-Worth Couples in Divorce
Divorce is not a topic most clients or tax advisors enjoy discussing.
Biden's American Families Plan Proposes Income Tax Hikes
The American Families Plan is the third part of the Biden Administration's Build Back Better agenda, addressing "human infrastructure" and containing proposals on free education, direct support to children and families, and the extension of tax cuts for families with children and American workers.
Large Corporations and Wealthy Taxpayers Beware: The Taxman is Coming
Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap1 in the U.S. may total $1 trillion per year.
Tennessee retains status as a leading trust jurisdiction
On May 12, 2021, Tennessee Governor Bill Lee signed into law a bill containing several revisions to Tennessee’s Uniform Trust Code (the “TN UTC”).
When IRS Penalty Assertions Are Unlawful
One of the most highly litigated issues in U.S. Tax Court is whether taxpayers are liable for certain penalties, additions to tax or additional amounts (each, a "penalty" and collectively, "penalties").
U.S. Supreme Court Decision May Pave Way for Future IRS Lawsuits
The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the Internal Revenue Service (IRS), delivering an important victory to CIC and similarly situated taxpayers everywhere.
Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy
By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government.
Biden Administration's FY 2022 Budget and International Tax Changes
A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy," June 3, 2021.)
The Green Book and Green Energy
Biden Administration's Budget Proposal Expands, Extends and Creates Tax Credits for Renewable Energy
Agreement on Global Tax Reform: What Happened and What's Next
Addressing the tax challenges arising from the digitalization of the economy has been a top priority of the Base Erosion Profit Shifting (BEPS) project of the Organization for Economic Cooperation and Development (OECD)/G-20 Inclusive Framework (IF)1 since 2015.
How Can the Same Right Create 2 Separate Property Interests?
A Closer Look at Taxpayers' Property Rights, State Laws and the Legitimacy of IRS Liens/Levies
IRS Promotes Use of Fallback Language to Assist with Libor, IBOR Transition
The Internal Revenue Service (IRS) released Revenue Procedure 2020-44 to assist the market's transition from the London Interbank Offered Rate (Libor) and other interbank offered rates (IBORs) to alternative reference rates by promoting the adoption of fallback language recommended by the...
U.K., U.S. Reach Competent Authority Agreement on "Equivalent Beneficiary" Status
The United Kingdom and the U.S. Competent Authorities published on July 28, 2021, a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty).1
Offshore Lenders Targeted by IRS Audit Campaign
Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations, premised on strategically identified and prioritized areas of compliance risks to address taxpayer compliance.
IRS Extends Time Period of Telephonic Public Approval Hearings for Private Activity Bonds
The Internal Revenue Service (IRS) has released Revenue Procedure 2021-39, which extends the time period for telephonic Tax Equity and Fiscal Responsibility Act (TEFRA) hearings until March 31, 2022.
IRS Adds a Potential Self-Dealing Transaction to the No-Rule List
The IRS issued Revenue Procedure 2021-40, 2021-38 IRB 1 on Sept. 3, 2021, adding a private foundation issue to the list of those areas on which the IRS will no longer issue private letter rulings or determination letters: The IRS indicated that it is "currently reviewing" its prior ruling position..
Regulatory Changes Impact Leasehold Condominiums in New York
The leasehold condominium structure has become a popular way for landlords and nonprofit entities to establish or modify their relationship to permit space that the nonprofit would formerly lease to qualify for a real property tax exemption.
Regulatory Changes Impact Leasehold Condominiums in New York
The leasehold condominium structure has become a popular way for landlords and nonprofit entities to establish or modify their relationship to permit space that the nonprofit would formerly lease to qualify for a real property tax exemption.
NBAA Article Explains IRS Stance on Entertainment Disallowance for Sole Proprietors
The Internal Revenue Service (IRS) recently released Chief Counsel Advice (CCA) 2021-17-012 to explain that sole proprietor flights are generally not subject to the employer-provided aircraft rules in Internal Revenue Code Section 274
House Ways and Means Committee Tax Plan Proposes Changes to Estate Planning
The House Committee on Ways and Means has proposed a tax plan intended to fund President Joe Biden's "Build Back Better" $3.5 trillion infrastructure program.
Maintaining Privilege with Non-Lawyer Experts Under Kovel
Holland & Knight Partners Abbey Garber and Denise Mudigere, along with Associate Kate Minnich, co-authored an article in the December 2021 issue of Headnotes, a publication of the Dallas Bar Association.
Update for Employers: Recent Legislation Improves, Extends Employee Retention Credit
The Coronavirus Aid, Relief, and Economic Security (CARES) Act authorized a refundable tax credit important to many employers struggling as a result of the COVID-19 pandemic.
Same Statute, Same Form, Different Penalties: Welcome to FBAR Litigation
The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation.
Increased Hart-Scott-Rodino Thresholds Set to Take Effect Feb. 23, 2022
The Federal Trade Commission (FTC) has announced this year's revisions to the thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (HSR), which will apply to all transactions closing on or after Feb. 23, 2022.
IRS Issues Favorable Tax Regulations on Management Company Exception to FET
Over the past few years, the Internal Revenue Service (IRS) has worked to issue final regulations that provide guidance to aircraft management companies and aircraft owners regarding their federal excise tax (FET) obligations.
Proposed Regulations Greatly Expand Guidance on Required Minimum Distributions
The Internal Revenue Service (IRS) issued expansive proposed regulations (the Proposed Regulations) on Feb. 24, 2022, reflecting the required minimum distribution (RMD) rules as set out in the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019 and providing significant...