Michael Silva > DLA Piper LLP (US) > Miami, United States > Lawyer Profile

DLA Piper LLP (US)
200 SOUTH BISCAYNE BOULEVARD
SUITE 2500
MIAMI, FL 33131-5341
United States
Michael Silva photo

Work Department

International Tax Counsel; Tax

Position

Partner

Career

Michael Silva focuses his practice on international tax law, with emphases on US investment structures, cross-border tax issues, tax treaty planning, withholding obligations of US real property investments and US activities of foreign banks. He has significant experience providing counsel in connection with the Foreign Account Tax Compliance Act (FATCA), a complex, unilateral US tax legislation that imposes third-party reporting obligations on global financial entities.

As a part of his practice, Michael:

Advises Brazilian and Asian investors and funds on investments in US real estate projects;
Assists multinational corporations seeking to establish a business presence in the US;
Establishes foreign trusts, corporations and advises clients on gratuitous transfers of wealth, including the US reporting requirements imposed on foreign trusts with US beneficiaries;
Advises financial institutions, insurers, broker-dealers, custodians, funds, fund advisers and managers, trust companies and other financial intermediaries in connection with the requisite protocols and procedures to validate compliance with FATCA requirements;
Advises clients in connection with local law and cross-border issues resulting from FATCA, such as conflicts of interest, privacy, data protection and transfer, client consents and complaints, consumer protection, regulatory interaction, account opening/closing requirements and nationality discrimination and reputational risk;
Assists local governments and industry groups entering into IGAs and structuring operations to obtain alternative FATCA classifications;
Assists international banks on US loans and other US activities;
Advises foreign clients on the US income, estate and gift tax consequences of alternative inbound investment structures while utilizing income, estate and gift tax treaties to minimize tax and regulatory burdens;
Represents US, Brazilian and Asian investors in the Angolan markets, including the telecomm, petroleum and mining, real estate, healthcare and farming sectors;
Advises on all aspects of withholding obligations on dispositions of US real property interests;
Represents estates of foreign and domestic decedents with property located in multiple jurisdictions;
Represents financial institutions in connection with payments made to nonresident aliens and beneficiaries of nonresident alien decedents;
Advises on domestic wills, trusts and other testamentary documents, including charitable, personal residence and qualified domestic trusts.

Languages

Portuguese, Spanish

Education

J.D., University of Florida; M.Acc., University of Florida; B.S., University of Florida

Lawyer Rankings

Latin America: International firms > City focus: Miami

DLA Piper LLP (US)‘s Miami office is playing an anchor role in the firm’s recently developed and geographically expansive Latin America practice. The Miami team has experienced a significant uptick in engagements from Chinese and European multinationals, multilatinas and other Latin American entities, including family offices, and has developed an especially strong record in financial services and insurance, energy, natural resources, agribusiness, and hospitality and hotels. Much of the practice centres on M&A and project development. The firm’s growing credentials in private equity have led to growth in financial sponsor investment engagments in Latin America; global co-chair of the corporate and private equity practice Joseph Alexander splits his time between the Dallas, Miami and New York offices. The Miami team has worked alongside colleagues in other offices to support clients on Argentine and Peru PPP projects, and has developed a healthy market share of Colombian 4G toll road project mandates.  A team led by Miami partner Francisco Cerezo, the US head of Latin America corporate, advised QBE Insurance Group on the sale of its Latin America business to Zurich, making Zurich the leading insurer in Argentina and a top three player in Ecuador. He also advised Costa Rican cable operator, Cabletica, on its $250m sale of a controlling interest to Liberty Latin America; Televisora de Costa Rica has retained a 20% share in the cable operator. John Murphy is another pivotal member of the Latin America team and has a fine record in project development, project finance and M&A in the region. Of counsel Diego Figueroa-Rodriguez is noted for tax-driven financing structures, including capital markets offerings and project finance engagements. Partner Michael Silva is another tax specialist, with a fine record in US investment structures and FATCA issues for Latin American investors.