Tax Compliance
The University of San Diego School of Law – Procopio International Tax Institute Covers Topics of Interest for Expatriation
By Patrick W. Martin
· October 31, 2014 · Updated June 3, 2026
The 10th annual conference, going on right now in San Diego, covers several courses of interest to those who are considering renouncing U.S. citizenship or abandoning their lawful permanent resident status.
The courses include the following (October 30 and 31):
Course 2A: Recent Developments in Individual International Tax Compliance
David Horton, Esq., – Director, International Individual Compliance – IRS
Patrick W. Martin, Esq. – Procopio
Course 5A:International Tax Audits & International Tax Appeals
Moderator: Eric D. Swenson, Esq. – Procopio
Ms. Ursula Gee, Esq. – IRS Examination Division
Russell McGeehan, Esq. – IRS Appeals Division
Lic. Sergio Luís Pérez – PriceWaterhouseCoopers
Beth Wapner, Esq., Vice President Tax and Trade – Qualcomm Inc.
Lic. Sergio A. Lopez Solano – Representative of the International Tax Audit Administration– SAT
Course 6B: OVDP – Opt Out with New IRS 2014 Rules
Jon P. Schimmer, Esq. – Procopio
Daniel Price, Esq., Chief Counsel for Abusive Tax Avoidance Transactions at SBI
Martin Press, Esq. – Gunster LLP
Course 8A:OVDP Civil FBAR Penalities After Zwerner
Patrick W. Martin, Esq. – Procopio
Martin Press, Esq. – Gunster LLP
Steven Toscher, Esq. – Hochman, Salkin, Rettig, Toscher & Perez P.C.
Course 10B:International Transactions and Title 31 Asset Forfeiture Actions
Patrick W. Martin, Esq. – Procopio
Richard Pietrofeso, Esq.– Area Counsel – Criminal Investigations, IRS
Daniel Silva, Esq., Assistant U.S. Attorney – Department of Justice (DOJ)
Maria Alvarez, Esq., Special Agent – Criminal Investigations, IRS
Wayne McEwan, Esq. – Wayne A McEwan & Associates
Patrick W. Martin
U.S. International Tax Lawyer · Shareholder, Chamberlain Hrdlicka
Patrick W. Martin is a U.S. tax lawyer licensed in California, Texas, and Washington, D.C., with 32+ years advising on the tax consequences of renouncing U.S. citizenship or abandoning lawful permanent residency. He served as lead counsel in Aroeste v. United States, the landmark federal case on green card holders, tax treaties, and the exit tax. Best Lawyers in America® (Tax Law), 2015–2025.
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