Practices

Taxation
International and Cross Border Transactions

Education

University of Florida College of Law, J.D., with honors
University of Florida, Masters, accounting
New York University School of Law Masters of Law, LL. M., taxation
University of Florida, B.S., accounting

Bar Admissions

Florida
New York

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Jeffrey "Jeff" Rubinger

Partner
Ft Lauderdale
t: 954-468-7862

Jeffrey L. Rubinger practices in the area of domestic and international taxation and is the head of the South Florida tax practice group. He has been involved in tax planning for mergers and acquisitions, restructurings and joint ventures, and in the structuring of tax-driven financial products. In addition, Mr. Rubinger has experience in a broad range of transactions involving U.S. taxpayers doing business overseas, foreign taxpayers conducting business in the United States, as well as federal, state and local tax issues involving corporate reorganizations, partnerships, Subchapter S corporations, qualified and non-qualified stock option plans, and trust and estates.

Mr. Rubinger lectures and has published several articles dealing with various domestic and international tax topics, including the Taxation of Financial Products, the Foreign Investment in Real Property Tax Act, International Tax Consequences of Cancellation of Indebtedness Income, the Taxation of Qualified Subchapter S Subsidiaries, “Check-the-Box” Tax Planning, Subpart F Income Minimization, Foreign Tax Credit Planning, and Tax Planning with Foreign Holding Companies.

Prior to attending law school Mr. Rubinger practiced as a Certified Public Accountant at a major accounting firm and holds an inactive Certified Public Accountant license from the State of Florida.

In the community, Mr. Rubinger is involved with the United Jewish Federation of Broward County.

Mr. Rubinger is adjunct tax professor at the University of Miami School of Law, LL.M. in Taxation Program and a member of the Board of Advisors and regular columnist on the tax aspects of licensing for the Licensing Journal.

Mr. Rubinger has authored numerous legal articles for publications, including:

Published Articles & Books

  • "New U.S.-Canada Treaty Protocol Will Affect Both Inbound and Outbound Investments," Business and Tax, Alert - September 30, 2008
  • "IRS Rules That Derivative Contract Tied to U.S. Real Property Index Is Not Subject to FIRPTA," Business and Tax, Alert - August 27, 2008
  • "U.S. International Tax Planning for Offshore Hotel and Resort Developments," Hospitality Industry, U.S. International Tax Planning for Offshore Hotel and Resort Developments Alert June 2, 2008
  • "IRS Provides Safe Harbor for “Dwelling Units” Exchanged as Part of Section 1031 (Like-Kind) Exchange," Real Estate, Newsletter - 1st Quarter 2008
  • "International Tax Aspects of Cancellation of Indebtedness Income," Journal of Taxation, June 2003
  • "IRS Informally Approves the Use of Hybrid Instrument to Create Cross-Border 'Double Dip'," Derivatives Report, December 2006
  • "The New U.K.-U.S. Agreement on Dual Consolidated Losses," Tax Notes International, November 2006
  • "Proposed Regulations Would Shut Down Guardian and Reverse Hybrid Structures," Derivatives Report, October 2006
  • "Tax Efficient Financing for Foreign Investment in U.S. Oil and Gas Sector," Oil & Gas Financial Journal, October 2006
  • "IRS Misses the Mark on Disallowing Loss in a Busted Section 351 Transaction," Journal of Taxation, July 2006
  • "Taxation of Variable Prepaid Forward Contracts Uncertain (Once Again) In Light of Recent TAM," Journal of Taxation, May 2006
  • "Revised Rules on Source of Income from Space Ocean, and International Communications," Journal of Taxation, January 2006
  • "Foreign Investors in U.S. Real Estate Should Consider Shared Appreciation Mortgages," Journal of Taxation, October 2005
  • "Final and Temp. 1446 Regs. Provide Relief With Respect to Income Allocated to Foreign Partners," Journal of Taxation, September 2005
  • "Assessing and Collecting U.S. Taxes from Non-U.S. Taxpayers," Tax Notes, June 2005
  • "Disguised Sales of Partnership Interests," Business Entities, May/June 2005
  • "Proposed Regulations on Cross-Border Mergers Will Add Much Flexibility in Planning," Journal of Taxation, May 2005
  • "Dvidends Received from Qualified Foreign Corporations - Recent Developments Change the Landscape," Tax Management International Journal, February 2005
  • "Holdings Intangibles Offshore May Produce Tangible Tax Benefits," Tax Notes, February 2005
  • "When Common Sense Failed: The Long-Tern Capital Holdings Decision and its Implications for Tax Planning," Derivatives Report, October 2004
  • "Tax Court Upholds Check-and-Sell Strategy to Avoid Subpart F Income: Has Pandora’s Box Been Opened? (Part I)," The M&A Tax Report, September 2004
  • "Final Regulations on Capitalization of Intangible Assets," Derivatives Report, May 2004
  • "Making Something out of Nothing (and Vice Versa) - Inconsistent Treatment of Tax Nothings," Journal of Taxation, November 2003
  • "IRS Reverses Position on Treatment of Stapled Foreign Entities for Foreign Tax Credit Purposes," Derivatives Report, September 2003
  • "International Tax Aspects of Cancellation of Indebtedness Income," June 2003
  • "Can a Total Return Equity Swap Avoid FIRPTA?," Journal of Taxation of Financial Products, Spring 2003
  • "IRS Shuts Down Partnership and Other Pass Through Entity Straddle Tax Shelters," Derivatives Report, January 2003
  • "IRS Starting to Challenge Popular Tax Deferral Technique," The Florida Bar Journal, January 2003
  • "Recent FSA's May Provide Guidance on the Taxation of Popular Hedging/Monetization Transaction," Journal of Taxation, August 2002
  • "Tax Treatment of Payments by Domestic Reverse Hybrid Entities: Final Regs. Issued," Derivatives Report, August 2002
  • "Are the Cards Stacked Against the DECS?," Derivatives Report, June 2002
  • "Tax Planning Strategies with Equity Derivatives," The Florida Bar Journal, April 2002
  • "Proposed Regulations Dealing with Qualified S Corporation Subsidiaries Issues by the Service," Journal of S Corporation Taxation, Fall 1998
  • "S Corporations: Long-Awaited Proposed Regulations on S Corporation Subsidiaries Issued," Journal of Partnership Taxation, Fall 1998
  • "Partnership Law: Recent Developments," Journal of Partnership Taxation, Summer 1998