Patrick W. Martin is a U.S. tax lawyer licensed in Washington D.C., Texas and California and specializes in international tax and related international law-matters. Mr. Martin is the partner in charge of the international tax practice group with the law firm of Procopio et al LLP where he practices exclusively in international tax.
He has advised clients for nearly three decades regarding the U.S. international tax and related legal consequences of renouncing U.S. citizenship or abandoning lawful permanent residency.
He was identified by his peers in the Best Lawyers in America® (Tax Law) – 2015, 2016, 2017, 2018 and 2019.
Outside of tax law, he is a passionate underwater cave explorer in the labyrinth of caves (thousands of kilometers) within the Yucatan peninsula. He received membership into the Explorer’s Club in 2019 for his cave exploration work. Photo below of friend and world renowned cave explorer Robbie Schmittner. Founded in New York City in 1904, The Explorers Club promotes the scientific exploration of land, sea, air, and space by supporting research and education in the physical, natural and biological sciences. The Club’s members have been responsible for an illustrious series of famous firsts: First to the North Pole, first to the South Pole, first to the summit of Mount Everest, first to the deepest point in the ocean, first to the surface of the moon—all accomplished by [Explorer’s Club] members.
He is a past Chair of the Taxation Section of the State Bar of California, Taxation Section. He was awarded the V. Judson Klein Award by the Taxation Committee of the State Bar of California in 2010. He received his law degree, J.D. from the University of San Diego School of Law, where he received the distinguished alumni award in 2013. He passed the Certified Public Accountant’s exam in the 1980s, previously worked for the Internal Revenue Service, and studied postgraduate law studies in international law – business transactions at the Escuela Libre de Derecho, in Mexico City in the 1990s.
He also regularly represents taxpayers before the IRS in international tax audits and litigates against the IRS vis-a-vis the Office of Chief Counsel lawyers of the IRS (in U.S. Tax Court) and attorneys from the Tax Division, Department of Justice (in U.S. District Court and the U.S. Court of Federal Claims). Reach him at 619.515.3230 or email@example.com
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June 8, 2016 at 4:37 am
As a dual citizenship single person, with no income this year, selling house for roughly half million, and wishing to expat. I understand I would not owe capital gains when I have no income this year, correct? Should I sell and deposit money in US banks, then move to foreign country and renounce US citizenship? Or buy foreign house first, then renounce? I don’t understand mark to market tax implications. Or should I renounce before buying foreign house? Will I be able to move money out of US banks after renouncing, having no travel possibility back to US? Should I open foreign account before renouncing, and move money there? Or should I buy foreign house, then do US income taxes next year, declare all foreign accounts, then renounce? Thanks for your input.