Michael Silva > DLA Piper LLP (US) > Miami, United States > Lawyer Profile
DLA Piper LLP (US) Offices
200 SOUTH BISCAYNE BOULEVARD
SUITE 2500
MIAMI, FL 33131-5341
FLORDIA
United States
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Michael Silva
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
Education
J.D., University of Florida; M.Acc., University of Florida; B.S., University of Florida
Top Tier Firm Rankings
- Media, technology and telecoms > Cyber law (including data privacy and data protection)
- Tax > International tax
- Real estate > Land use/zoning
- Investment fund formation and management > Alternative/hedge funds
- Media, technology and telecoms > Outsourcing
- Intellectual property > Patents: licensing
- Intellectual property > Patents: litigation (International Trade Commission)
- Dispute resolution > Product liability, mass tort and class action - defense: pharmaceuticals and medical devices
- Real estate > Real estate
- Government > State attorneys general
- Media, technology and telecoms > Telecoms and broadcast: regulatory
- Media, technology and telecoms > Telecoms and broadcast: transactions
Firm Rankings
- Media, technology and telecoms > Advertising and marketing: transactional and regulatory
- Industry focus > Cannabis
- Antitrust > Cartel
- Dispute resolution > E-discovery
- Tax > Financial products
- Finance > Fintech
- Intellectual property > Patents: litigation (full coverage)
- Dispute resolution > Product liability, mass tort and class action - defense: toxic tort
- Real estate > Real estate investment trusts (REITs)
- Energy > Renewable/alternative power
- Finance > Structured finance: securitization
- Media, technology and telecoms > Technology transactions
- Intellectual property > Trademarks: non-contentious (including prosecution, portfolio management and licensing)
- Tax > US taxes: contentious
- M&A/corporate and commercial > Venture capital and emerging companies
- Labor and employment > Workplace and employment counseling
- Insurance > Advice to insurers
- Intellectual property > Copyright
- Environment > Environment: regulatory
- Insurance > Insurance: non-contentious
- Labor and employment > Labor and employment disputes (including collective actions)
- Labor and employment > Labor-management relations
- Healthcare > Life sciences
- Dispute resolution > M&A litigation: defense
- Dispute resolution > Product liability, mass tort and class action - defense: automotive/transport
- Dispute resolution > Product liability, mass tort and class action - defense: consumer products (including tobacco)
- Dispute resolution > Securities litigation: defense
- Intellectual property > Trademarks: litigation
- Tax > US taxes: non-contentious
- Finance > Capital markets: equity offerings
- Antitrust > Civil litigation/class actions: defense
- Real estate > Construction (including construction litigation)
- Labor and employment > Employee benefits, executive compensation and retirement plans: transactional
- Environment > Environment: litigation
- Environment > Environment: transactional
- Dispute resolution > General commercial disputes
- Dispute resolution > International arbitration
- Media, technology and telecoms > Media and entertainment: litigation
- Media, technology and telecoms > Media and entertainment: transactional
- Intellectual property > Patents: prosecution (including re-examination and post-grant proceedings)
- M&A/corporate and commercial > Private equity buyouts: large deals ($500m+)
- Investment fund formation and management > Private equity funds (including venture capital)
- Healthcare > Service providers
- Intellectual property > Trade secrets (litigation and non-contentious matters)
- M&A/corporate and commercial > M&A: large deals ($1bn+)
- Finance > Project finance
- Dispute resolution > Corporate investigations and white-collar criminal defense