Jennifer A. Migliori practices in the area of U.S. domestic and international taxation, wealth transfer planning and business transactions. Ms. Migliori assists multijurisdictional U.S. and offshore clients with tax-minimization strategies. She has experience developing and implementing tax-efficient cross-border investment structures. Ms. Migliori also assists families with generational wealth and asset transfers and pre-immigration tax planning. Her practice includes entity and trust formation. She also counsels clients on matters concerning asset protection, business succession planning, and the formation and maintenance of for-profit and not-for-profit organizations.
Ms. Migliori has experience working with financial institutions, accountants, and advisors in connection with the U.S. tax treatment of U.S. and foreign-based assets. This includes advice concerning the withholding of tax on resident and nonresident aliens and foreign entities, compliance with federal tax and information reporting requirements, and addressing tax issues arising under the Foreign Investment in Real Property Tax Act (FIRPTA), in connection with the acquisition and sale of U.S. real estate by foreign persons. She has developed an expertise in the various international information sharing arrangements, and regularly advises clients and their advisors on compliance issues arising under U.S. tax treaties, the Foreign Account Tax Compliance Act (FATCA), exchange of information agreements, and the Common Reporting Standard (CRS). In addition, she assists clients with tax controversy matters including audit representation and voluntary disclosures.
Prior to law school, Ms. Migliori worked as a tax accountant at KPMG LLP, and as a financial controller.
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).
Areas of Practice
- Strategic Tax Planning
- Wealth Transfer Planning
- Corporate Law
- 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 School of Business Administration, B.B.A., Accounting, magna cum laude, 2006
- Duane Morris LLP
- Carlton Fields Jorden Burt P.A.
- Holland and Knight LLP
- Transworld Services, Inc.
- Financial Operations Director
- KPMG LLP
- Federal Tax Associate
- 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.
- Florida Bar
- Tax Section
- Real Property Probate and Trust Law Section
Selected Speaking Engagements
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
Co-author, "Florida’s Budding Cannabis Industry Expands With New Hemp Law," Daily Business Review, July 1, 2019