Jennifer A. Migliori practices in the area of domestic and international taxation and business transaction planning. Ms. Migliori assists multijurisdictional clients with tax-minimization strategies and has experience developing and implementing tax-efficient investment structures. Her practice includes entity and trust formation. She also counsels clients on matters concerning the formation and maintenance of for-profit and not-for-profit organizations.
Ms. Migliori has experience representing investors, fund managers, family offices, financial institutions and advisors. In connection with the acquisition and sale of U.S. real estate, she has experience addressing tax issues arising under the Foreign Investment in Real Property Tax Act (FIRPTA) and 1031 like-kind exchange transactions. She has developed a focus on the various international information sharing arrangements, and regularly advises clients and their advisors on issues arising under tax treaties, the Foreign Account Tax Compliance Act (FATCA), exchange of information agreements and the Common Reporting Standard (CRS). In addition, she frequently assists clients with expatriation and pre-immigration tax planning and tax controversy matters, including audit representation and voluntary disclosures.
Ms. Migliori is admitted to practice law in Florida and Pennsylvania, and before the U.S. Tax Court. Ms. Migliori earned her LL.M. in Taxation from the New York University School of Law and her law degree from University of Virginia School of Law, where she was Editor-in-Chief of the Virginia Tax Review. She is a magna cum laude graduate of the University of Miami School of Business, where she studied accounting. She is a graduate of the Florida Fellows Institute of the American College of Trust and Estate Counsel (ACTEC).
Ms. Migliori is fluent in English and Spanish.
Areas of Practice
- Strategic Tax Planning
- Wealth Transfer Planning
- Corporate Law
- Represented high-net-worth family in connection with cross-border tax planning, redomiciled trust and domesticated foreign corporations after some members of the family relocated to the United States.
- Assisted with the creation of a non-resident trust to hold foreign assets for the benefit of U.S. beneficiaries of Mexican family, further advised as to the U.S. tax consequences of U.S. resident beneficiaries.
- Guided dozens of high-net-worth clients through IRS examinations and Foreign Bank Account Reporting compliance.
- Represented U.S. citizen in avoiding criminal sanctions in an investigation by IRS special agents and attorneys from the United States Department of Justice.
Represented large technology company during IRS examination in connection with employment taxes and withholding taxes, and tax planning in connection with global restructuring of operations in order to minimize U.S. income tax exposure.
- Guided International Trust Company in assessing its FATCA and U.S. tax compliance obligations with respect to U.S. beneficiaries.
- Represented foreign developer of self-storage facilities in the acquisition of facility sites in the United States.
- Represented out-of-state trust company in establishing Florida presence.
- Represented Goldman Sachs Lending Partners in a $700 million Senior Secured First Lien Term Loan Facility and $50 million Senior Secured First Lien Revolving Facility together with other security, credit, hedging and financing, resulting in an aggregate principal financing estimated to be $1.1 billion, with funding to be used to restart an oil refinery in the U.S. Virgin Islands.
- U.S. Tax Court
- New York University School of Law, LL.M., Taxation, 2014
- University of Virginia School of Law, J.D., 2013
- Editor-in-Chief, Virginia Tax Review
- University of Miami Herbert Business School, B.B.A., Accounting, magna cum laude, 2006
- Duane Morris LLP
- Carlton Fields Jorden Burt P.A.
- Holland and Knight LLP
- Florida Bar
- Tax Section
- Real Property Probate and Trust Law Section
- International Bar Association
- Taxes Committee
- Co-author, "Chapter 105 (Taxes) of Immigration Law and Procedure," LexisNexis, 2021
- Co-author, "How Will the Anti-Money Laundering Act of 2020 Affect Bank Secrecy Act Compliance for Financial Institutions?" Duane Morris Alert, March 10, 2021
Co-author, "Florida’s Budding Cannabis Industry Expands With New Hemp Law," Daily Business Review, July 1, 2019
- Co-author, "New FIRPTA Exceptions Provide Opportunities for Foreign Pensions and Investment Funds," Carlton Fields Client Alert, February 2016
Selected Speaking Engagements
Panelist, “Tax Transparency and Social Responsibility – Managing Opportunities and Risks of Ever Complex Tax Laws,” The Next Era of Taxation Conference, International Bar Association Taxes Committee, December 3, 2021
Speaker, Tax Issues in Cannabis and Commercial Real Estate, 6th Annual NAI Florida & Caribbean Conference, November 14, 2019
Panelist, "Helping International Clients Invest in the U.S. and Stay," Financial Planning Association of Miami Practice Management Breakfast, May 22, 2019
Panelist, Latin America & Caribbean Session, 5th Annual NAI Florida Conference, November 15, 2018
- Presenter, "Cross-Border Tax and Wealth Planning," FY International Annual Summit Miami 2017, August 24, 2017
- Speaker, "Pre-immigration Tax Planning Strategies," Leumi Third Annual Private Bank Investment Conference, December 5, 2016
- Speaker, "FATCA and the Common Reporting Standard, Planning for Non-U.S. Persons," Pan-American Private Client Life Professional Development Workshop, May 23, 2016