Holland + Knight
Jeffrey L. Rubinger
practices in the area of domestic and international taxation and is the
head of the South Florida tax practice group. He has been involved in
tax planning for mergers and acquisitions, restructurings and joint
ventures, and in the structuring of tax-driven financial products. In
addition, Mr. Rubinger has experience in a broad range of transactions
involving U.S. taxpayers doing business overseas, foreign taxpayers
conducting business in the United States, as well as federal, state and
local tax issues involving corporate reorganizations, partnerships,
Subchapter S corporations, qualified and non-qualified stock option
plans, and trust and estates.
Mr. Rubinger lectures
and has published several articles dealing with various domestic and
international tax topics, including the Taxation of Financial Products,
the Foreign Investment in Real Property Tax Act, International Tax
Consequences of Cancellation of Indebtedness Income, the Taxation of
Qualified Subchapter S Subsidiaries, "Check-the-Box" Tax Planning,
Subpart F Income Minimization, Foreign Tax Credit Planning, and Tax
Planning with Foreign Holding Companies.
Prior to attending law
school Mr. Rubinger practiced as a Certified Public Accountant at a
major accounting firm and holds an inactive Certified Public Accountant
license from the State of Florida.
In the community, Mr. Rubinger is involved with the United Jewish Federation of Broward County.
Mr. Rubinger is adjunct
tax professor at the University of Miami School of Law, LL.M. in
Taxation Program and a member of the Board of Advisors and regular
columnist on the tax aspects of licensing for the Licensing Journal.
Mr. Rubinger has authored numerous legal articles for publications, including:
Professional Honors & Awards
- The Best Lawyers in America guide, 2009
- Florida Super Lawyers magazine, 2009
Published Articles & Books
- "Proposed Conduit Financing Regulations Treat Disregarded Entities as Regarded Entities," Business and Tax, Alert - February 25, 2009
- "Proposed Regulations Allow Taxpayers to Avoid Current Gain Recognition Under Section 367," Journal of Taxation, November 2008
- "New U.S.-Canada Treaty Protocol Will Affect Both Inbound and Outbound Investments," Business and Tax, Alert - September 30, 2008
- "IRS Rules Total Return Swap Tied to Real Estate Index is not subject to FIRPTA," Journal of Taxation, September 2008
- "IRS Rules That Derivative Contract Tied to U.S. Real Property Index Is Not Subject to FIRPTA," Business and Tax, Alert - August 27, 2008
- "U.S. International Tax Planning for Offshore Hotel and Resort Developments," Hospitality Industry, U.S. International Tax Planning for Offshore Hotel and Resort Developments Alert June 2, 2008
- "Proposed contract manufacturing Regs. May Help Taxpayers Avoid Subpart F Income," Journal of Taxation, May 2008
- "IRS Provides Safe Harbor for "Dwelling Units" Exchanged as Part of Section 1031 (Like-Kind) Exchange," Real Estate, Newsletter - 1st Quarter 2008
- "Tax Treatment of ETNS and Prepaid Forward Contracts Under Fire," Derivatives Report, February 2008
- "Moving the Management and Control of a Foreign Corporation to Achieve Favorable U.S. Tax Results, Part II," Florida Bar Journal, November 2007
- "Management and Control: Should Place of Formation Determine U.S. International Tax Consequences?," International Taxation, October 2007
- "Moving the Management and Control of a Foreign Corporation to Achieve Favorable U.S. Tax Results, Part I," Florida Bar Journal, October 2007
- "Moving the Management and Control of Foreign Corporations to Achieve Favorable U.S. Tax Results," Corporate Business Taxation Monthly, October 2007
- "Moving Management and Control of a Foreign corporation to achieve favorable U.S. Tax Results," Journal of Taxation, August 2007
- "Treaty Shopping: Is it Still a Viable Option?," Corporate Business Taxation Monthly, May 2007
- "IRS Issues Safe Harbor for Certain Cross-Licensing Arrangements," Licensing Journal, April 2007
- "Tax Planning with U.S. Income Tax Treaties Without LOB Provisions," International Journal, March 9, 2007
- "CFC Look-Through Rule: Needed Clarification," Tax Notes, Vol. 114, February 26, 2007
- "Proposed Technical Taxpayer Regulations Shut Down Guardian and Reverse Hybrid Structures," Florida Bar Journal, February 2007
- "Section 362(e)(2) Proposed Regulations Provide Clarity and Planning Opportunities," Journal of Taxation, February 2007
- "NJ Supreme Court Rules Out-of-State Intangible Holding Company Subject to NJ State Income Tax," Licensing Journal, January 2007
- "Section 901 Proposed Regulations Shut Down Guardian and Reverse-Hybrid Structures," International Taxation, January 2007
- "IRS Informally Approves the Use of Hybrid Instrument to Create Cross-Border 'Double Dip'," Derivatives Report, December 2006
- "New Currency Branch Regs Shut Down Abusive Loss Recognition," Tax Notes, Vol. 113, December 2006
- "IRS Disallows Deduction for Royalties Paid by U.S. Subsidiary to Its Foreign Parent," Licensing Journal, Nov/Dec 2006
- "The New U.K.-U.S. Agreement on Dual Consolidated Losses," Tax Notes International, November 2006
- "The New U.K.-U.S. Agreement on Dual Consolidated Losses," Tax Notes, Vol. 113, November 2006
- "Proposed Regulations Would Shut Down Guardian and Reverse Hybrid Structures," Derivatives Report, October 2006
- "Settlement of Copyright Infringement Is Not Excludable as an Involuntary Conversion," Licensing Journal, October 2006
- "Tax Efficient Financing for Foreign Investment in U.S. Oil and Gas Sector," Oil & Gas Financial Journal, October 2006
- "Section 367(d) Trumps Section 351(b) in Transfer of Intangible Property by U.S. Person to Foreign Corporation," Licensing Journal, August 2006
- "IRS Misses the Mark on Disallowing Loss in a Busted Section 351 Transaction," Journal of Taxation, July 2006
- "IRS Requests Comments on Cross-Licensing Arrangements," Licensing Journal, June/July 2006
- "IRS Rules that Swap Intangibles Not Eligible for Like-Kind Exchange Treatment," Licensing Journal, May 2006
- "Taxation of Variable Prepaid Forward Contracts Uncertain (Once Again) In Light of Recent TAM," Journal of Taxation, May 2006
- "Payments Received by Tax-Exempt Organization Are Non-Taxable Royalties," Licensing Journal, April 2006
- "IRS Limits Application of Foreign Tax Credit Disallowance Rules for Back-to-Back Licensing Agreements," Licensing Journal, March 2006
- "Using Shared Appreciation Mortgages to Avoid FIRPTA," Florida Bar Journal, March 2006
- "Trademark Holding Companies Challenge Imposition of State Tax," Licensing Journal, February 2006
- "Revised Rules on Source of Income from Space Ocean, and International Communications," Journal of Taxation, January 2006
- "Value Associated with Employee Stock Option Grants Need Not Be Treated as Shared Cost," Licensing Journal, January 2006
- "Will the IRS Impute Income in Cross-Licensing Agreements Between US and Foreign Companies?," Licensing Journal, Nov/Dec 2005
- "Federal Income Tax Consequences of Licensing and/or Selling IP among Related Parties," Licensing Journal, October 2005
- "Foreign Investors in U.S. Real Estate Should Consider Shared Appreciation Mortgages," Journal of Taxation, October 2005
- "Final and Temp. 1446 Regs. Provide Relief With Respect to Income Allocated to Foreign Partners," Journal of Taxation, September 2005
- "IRS Issues Guidance on Like-Kind Exchanges of Federal Communications Commission Licenses," Licensing Journal, September 2005
- "IRS Rules That LLC Members Remain Patent "Holders" for Capital Gain Purposes," Licensing Journal, August 2005
- "Congress Cracks Down on Charitable Contributions of Intellectual Property," Licensing Journal, June/July 2005
- "Assessment and Collecting U.S. Taxes from Non-U.S. Taxpayers," Tax Notes, June 2005
- "Disguised Sales of Partnership Interests," Business Entities, May/June 2005
- "Holding Intangibles Offshore May Produce Tangible Tax Benefits (continuation of April article...)," Licensing Journal, May 2005
- "Proposed Regulations on Cross-Border Mergers Will Add Much Flexibility in Planning," Journal of Taxation, May 2005
- "Proposed Regulations on Dividends Received from Qualified Foreign Corporations - Recent Developments Change the Landscape," Florida Bar Journal, May 2005
- "Holding Intangibles Offshore May Produce Tangible Tax Benefits," Licensing Journal, April 2005
- "Holdings Intangibles Offshore May Produce Tangible Tax Benefits," Tax Notes, February 2005
- "Notice 2005-10: IRS Guidance on Repatriation of Foreign Earnings Under Section 965," Derivatives Report, February 2005
- "Tax Planning After the Lessons of Long Term Capital," Tax Notes, Vol. 105, October 11, 2004
- "When Common Sense Failed: The Long-Tern Capital Holdings Decision and its Implications for Tax Planning," Derivatives Report, October 2004
- "Tax Court Upholds Check-and-Sell Strategy to Avoid Subpart F Income: Has Pandora's Box Been Opened? (Part I)," The M&A Tax Report, September 2004
- "Tax Court upholds "check and sell" strategy to avoid Subpart F income," Journal of Taxation, July 2004
- "Final Regulations on Capitalization of Intangible Assets," Derivatives Report, May 2004
- "Can FIRPTA Be Avoided With Financial Instruments?," Florida Bar Journal, March 2004
- "Making Something out of Nothing (and Vice Versa) - Inconsistent Treatment of Tax Nothings," Journal of Taxation, November 2003
- "IRS Reverses Position on Treatment of Stapled Foreign Entities for Foreign Tax Credit Purposes," Derivatives Report, September 2003
- "International Tax Aspects of Cancellation of Indebtedness Income," Journal of Taxation, June 2003
- "Can a Total Return Equity Swap Avoid FIRPTA?," Journal of Taxation of Financial Products, Spring 2003
- "IRS Shuts Down Partnership and Other Pass Through Entity Straddle Tax Shelters," Derivatives Report, January 2003
- "IRS Starting to Challenge Popular Tax Deferral Technique," The Florida Bar Journal, January 2003
- "Recent FSA's May Provide Guidance on the Taxation of Popular Hedging/Monetization Transaction," Journal of Taxation, August 2002
- "Tax Treatment of Payments by Domestic Reverse Hybrid Entities: Final Regs. Issued," Derivatives Report, August 2002
- "Are the Cards Stacked Against the DECS?," Derivatives Report, June 2002
- "Tax Planning Strategies with Equity Derivatives," Florida Bar Journal, April 2002
- "Proposed Regulations Dealing With Qualified S Corporation Subsidiaries Issues By The Service," Journal of S Corporation Taxation, Fall 1998
- "S Corporations: Long-Awaited Proposed Regulations S Corporation Subsidiaries Issued," Journal of Partnership Taxation, Fall 1998
- "Partnership Law: Recent Developments," Journal of Partnership Taxation, Summer 1998
The combination of a weak U.S. dollar and low interest rates has resulted in an enormous increase in foreign investment in U.S. real estate. (1) While investment is not expected to continue at the same pace, the U.S. is expected to remain the number one overall real estate market for non-U.S, investors. (2)
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