Leading an international tax team whose cases others cite as precedent.
Thirty-plus years across four connected practices — global families and family offices, cross-border M&A, tax controversy and litigation, and expatriation and treaty residency. Available for speaking engagements, press commentary, and professional referrals.
Patrick W. Martin advises privately held companies, global investors, and multinational families on cross-border tax treaty planning and worldwide investment structures — and defends them in international tax controversies before the IRS and in federal court. He earned his J.D. from the University of San Diego School of Law and studied international law at La Escuela Libre de Derecho in Mexico City.
Two rulings that rewrote how the IRS treats cross-border taxpayers — and Patrick argued both.
00682
Holland & Knight
Claims
appeal filing
(2023)
ACTEC
Two IRS private letter rulings that reshaped cross-border wealth planning for multinational families — and Patrick obtained both.
2002
confirmed
2015
secured
Together, the rulings show how carefully structured U.S.-administered foreign trusts can produce significant cross-border income, estate, and basis-planning opportunities for multinational families.
Find the track that matches why you’re here.
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Global Families, Private Client & Family OfficeFor family offices, private trust companies, fiduciaries and their advisors
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“More than thirty years devoted to the U.S. international tax and legal affairs of multinational families — their worldwide income, succession, trusts and holding arrangements, and family offices.”
Capabilities
- Pre-immigration & pre-expatriation planning
- Foreign trusts & U.S. beneficiaries (Forms 3520/3520-A)
- U.S. situs assets & non-domiciliary estate tax
- Private trust company & situs selection (South Dakota, Nevada, Delaware, Cayman, Bahamas, Liechtenstein, Singapore)
- Family office structuring & governance
Representative Matters
Directed pre-sale planning for a Mexican Pacific coastal property held through a Cayman–Delaware–Mexico chain, producing bilingual family executive summaries for principals and next-generation members.
Advises international entertainers, recording artists, film producers, and authors — including Grammy and Academy Award winners and New York Times best-selling authors — on the worldwide taxation of their creative assets and intellectual property. Fellow, ACTC & ACTEC.
Discuss a family or family-office matter →
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Cross-Border M&A & TransactionsFor funds, strategic buyers, founders and deal counsel
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“Thirty years of inbound and outbound acquisitions, joint ventures, fund formation and financing across the U.S.–Mexico and U.S.–Latin America corridor — with the controversy experience to make the arrangement hold up years later.”
Capabilities
- Acquisition & disposition planning, tax-free reorgs
- Treaty planning & cross-border financing
- CFC / GILTI / Subpart F / PFIC modeling
- Deal-stage information-reporting diligence
Representative Matter
Built the cross-border operating framework for a SaaS startup weighing a foreign subsidiary against a branch, including comparative CFC analysis and §1202 qualified small business stock planning.
Discuss a transaction →
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International Tax Controversy & LitigationFor taxpayers and counsel facing the IRS or DOJ Tax Division
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“Thirty years of examinations, appeals and federal litigation over international income, foreign assets, foreign accounts, and the penalties that attach to them.”
Capabilities
- FBAR penalty defense, willful & non-willful
- Assessable penalty defense (the Farhy line of cases)
- IRS examination & Independent Office of Appeals
- Refund litigation, Tax Court through Federal Circuit
- Cross-border criminal tax investigations & enforcement
Representative Matter
Negotiated a $13.3M tax recovery for a non-resident individual in a refund suit before the U.S. Court of Federal Claims, after the case had already been filed on appeal to the Federal Circuit. That refund-litigation experience carries over directly to taxrefundgamblers.com, his practice’s recovery platform for nonresident withholding refunds.
Discuss an exam or dispute →
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Expatriation & Treaty ResidencyFor citizens, green card holders, and their advisors
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“U.S. expatriation tax understood by the attorney who litigated its landmark case — and who has written the standing public reference on the subject since 2013.”
Capabilities
- Covered expatriate determination & §877A exit tax
- Long-term LPR / treaty tie-breaker (the Aroeste doctrine)
- The §2801 “forever taint” on covered gifts & bequests
- Form 8854, Certificate of Loss of Nationality
Representative Matter
Author and maintainer of tax-expatriation.com since 2013 — the resource tax lawyers and CPAs worldwide bookmark and cite on expatriation, green card and treaty residency taxation.
Discuss an expatriation matter →A litigator’s read on international tax, not just a planner’s.
Most international tax advice is written by people who have never had to defend it in front of a judge. Patrick has — as lead counsel in Aroeste v. United States, negotiator of a $13.3M recovery before the Court of Federal Claims, co-author of the ACTEC amicus brief cited in Bittner, and across three decades advising multinational families, global investors, and privately held companies through IRS audits, administrative appeals, and litigation before the U.S. Tax Court, Court of Federal Claims, and federal district courts.
He co-leads the international tax practice at Chamberlain Hrdlicka, named 2025 “Law Firm of the Year” in Tax and Tax Controversy by Best Lawyers, and has spent more than 20 years co-organizing the University of San Diego School of Law–Chamberlain International Tax Institute, one of the leading annual gatherings in U.S.–Mexico international tax. He also teaches international tax at law schools in the U.S. and abroad — including the Instituto Tecnológico Autónomo de México (ITAM) — and writes prolifically on the subject in tax journals worldwide.
That international outlook is personal as well as professional: he holds Mexican lawful permanent residency himself, and his family’s businesses outside the United States are run by his wife, herself an immigrant to the U.S. — the same cross-border life his clients are navigating.
He has also helped create more than $1M in endowed scholarship funds for legal education, principally at the University of San Diego School of Law, with additional scholarships facilitated at ITAM in Mexico City.
The practice is genuinely bilingual: he drafts, negotiates, and presents in English and Spanish.
Talks ready to give, drawn from active practice — not just PowerPoints.
Migration, Expatriation & Citizenship by Investment: The New Global Landscape with a “Gold Card”
Panel talk, 2026 International Tax Conference, Mérida (February 2026) — the tax mechanics of the proposed program set against the green card and EB-5.
Valuation Battles in the U.S. Tax Court (Foreign Assets on the Horizon)
Panel talk, 2026 International Tax Conference, Mérida (February 2026) — lessons from Estate of Cecil v. Commissioner for cross-border valuation disputes.
Foreign Trusts: New Regulations
Delivered at the Texas International Tax Symposium (2024) — the 2024 proposed regulations on foreign trust and foreign gift reporting.
Living in the Post-Grecian World: Withholding on Transfers of Partnership Interests
Delivered at the University of San Diego International Tax Institute (2019) — §1446(f) and §864(c)(8) after Grecian Magnesite.
FBAR Penalties: Defending Title 31, Pre- and Post-Assessment
Delivered at the University of San Diego International Tax Institute (2018) — IRS and DOJ policy and strategy following United States v. Colliot, the ruling that capped willful FBAR penalties at $100,000 under the pre-2004 regulation.
Reporting, Penalties & Recent Cases
Delivered at the NY State Bar Association’s 20th Annual International Estate Planning Institute (2025).
Tax Treaties for the Wealth Transfer Professional
Delivered at the Hawaii Tax Institute (2024) — treaty planning for cross-border estates and trusts.
Selected writing, linked to the source.
Recent Articles
Firm Tax Blog
Also Published
How other practitioners cite his work.
Reported the ruling as a major taxpayer win establishing that a tax treaty, not just domestic law, can govern whether FBAR reporting is required.
— Matthew Roberts, ForbesKPMG’s Washington National Tax practice flagged that the ruling opens a path for green card holders in other treaty countries to invoke the same benefit and avoid FBAR filing.
— KPMG, GMS Flash Alert 2023-226Analyzed in depth as a case with real implications for dual residents and the tension between treaty positions and FBAR filing obligations.
— Alan Granwell et al., Holland & Knight, Taxes MagazineDescribed as a possible method for a green card holder no longer living in the United States, and resident in a favorable treaty country, to avoid FBAR filing altogether.
— Virginia La Torre Jeker, J.D., US Tax TalkCovered in detail as a full case study of the government’s shifting position on treaty tie-breakers, FBAR exposure, and the exit tax.
— John Richardson, Citizenship SolutionsWalked through the ruling’s mechanics for the firm’s international-planning clients, including the residual $1,000-per-year penalty for the late treaty position filing.
— Hone Maxwell LLPUniversity of San Diego School of Law – Chamberlain International Tax Institute
The conference held annually by the University of San Diego School of Law–Chamberlain Hrdlicka Tax Institute is the premier international tax conference. For over 20 years, it has brought together tax practitioners, policymakers, and academics for cross-border and U.S.–Mexico tax issues.
Past speakers include former IRS Commissioner Chuck Rettig and former Banco de México Governor Agustín Carstens. Recent editions have been held in Mexico City (2023) and Mérida, Yucatán (2024, 2025, 2026).
Visit fiscal-tax.com →Co-Chair20+ years running
For speaking, press, or a professional referral — reach out directly.
Book Patrick for a conference or panel
Topics above, or tailored to your audience — exit tax, cross-border families, or litigation strategy.
inquiries@patrickwmartin.com →Commentary or interview requests
Available for comment on exit tax policy, cross-border enforcement, and international tax litigation.
inquiries@patrickwmartin.com →Refer a client or matter
Family office, cross-border M&A, tax controversy, or expatriation — each practice above has its own direct line.
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