Fernando Juarez Hernandez

Fernando focuses on international tax planning, cross-border structuring, and tax controversy matters for ultra-high-net-worth individuals, multinational families, private investors, and closely held businesses. Advises on inbound and outbound investment structures, FIRPTA planning, foreign trust matters, international estate and succession planning, and U.S. tax issues arising from cross-border operations and investments.

Represents clients in complex IRS examinations, Foreign Document Request enforcement, refund litigation in Federal Court. Practice also encompasses international tax compliance, offshore reporting, foreign information returns, and cross-border transactions. Regularly advises on matters involving Forms 3520, 5471, 8938, FBAR reporting, and other international tax disclosure and controversy issues.

Dallas Hispanic Bar Association

American Bar Association

* Advised a multi-jurisdictional family enterprise on global restructuring and international tax compliance in connection with holdings in a mining group with multinational operations, including foreign information reporting and treaty-based planning.

* Served as lead tax counsel on a $15 million corporate reorganization for an international privately held supplier to the U.S. automotive manufacturing industry.

* Reorganized the ownership structure of a $350 million U.S. real estate development for an ultra-high-net-worth family, preserving key estate planning objectives and avoiding adverse tax consequences.

* Serve as lead U.S. tax counsel to a national restaurant franchise group operating more than 70 locations nationwide, advising on domestic tax matters affecting the group’s continued growth and operations.

* Assisted a multinational business group with a global tax restructuring involving operations across multiple jurisdictions and international markets.

* Tax Counsel in a significant IRS enforcement matter involving Malta pension structures and a Formal Document Request, obtaining a favorable resolution regarding the scope and enforceability of the request.