Michael Bruno focuses his practice on domestic and international tax planning for multinational companies, closely held businesses, funds, and ultra-high net worth individuals. Michael has written numerous articles on international tax planning and frequently submits comments on statutory & regulatory promulgations.
Recently, through comments and presentation, Michael successfully advocated on behalf of the Florida Bar Tax Section for the IRS and Treasury to afford the Section 250 deduction to electing Section 962 shareholders that earn Global Intangible Low-Taxed Income (“GILTI”).
Michael regularly advises corporate clients and funds on mergers, acquisitions, restructurings and divestitures in a variety of business contexts. He has assisted companies with a number of international tax issues, including intellectual property migrations, Subpart F, GILTI, and FDII planning, foreign tax credit planning, tax-efficient cash repatriation strategies and post-acquisition integration and implementation. Michael also has experience in advising companies on cross-border tax matters involving technology, digital goods and services.
Michael also regularly advises foreign individuals on tax efficient mechanisms for doing business in the United States, investing in US real estate, and pre-immigration planning. He regularly advises US individuals on matters that include making investments and doing business outside the United States, expatriations,establishing qualified opportunity funds (“QOFs”) and general tax planning for US investments and business. He also has experience in advising athletes, entertainers, and related organizations on unique tax matters.
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