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Kevin E. Packman

Partner
Miami
t: 305-349-2261

Kevin E. Packman, a native of Miami, Fla., is a partner with Holland & Knight and a member of its International Estate Planning Group, an integral part of the firm's Private Wealth Services Department. He also chairs the firm's Offshore Compliance Team. His practice includes tax controversies, estate planning (domestic and international) and creditor protection planning. He is also recognized as a national leader in the area of Foreign Bank and Financial Accounts Reporting.

Mr. Packman has experience:

  • advising clients on Foreign Bank Account Reporting compliance
  • guiding clients through IRS examinations and audits
  • assisting domestic clients with preparation of estate plans to minimize gift and estate tax exposure
  • creating structures through which international clients may invest in the U.S., and avoid estate tax exposure
  • providing pre-immigration planning to foreign individuals planning to establish domicile in the U.S.
  • advising U.S. beneficiaries of foreign trusts and/or estates on alternatives to reduce U.S. taxes

Additionally, Mr. Packman has:

  • represented a non-resident alien in a criminal investigation by the United States Department of Justice resulting in no criminal charges being filed against the client
  • negotiated the release of an IRS levy against a non-resident alien client's investment account
  • resolved an IRS dispute with exposure in excess of $6 million involving income tax, gift tax and various penalty issues for failure to file Forms 3520 and 3520-A for $1.1 million
  • represented a client in avoiding criminal sanctions in an investigation by IRS special agents and attorneys from the United States Department of Justice

Mr. Packman has lectured for the AICPA, ABA, New York University, University of Miami, The Florida Bar and STEP. He has also presented to numerous national and community institutions/organizations. Mr. Packman is a prolific writer with articles appearing in a number of publications, including The Florida Bar Journal, Journal of Accountancy, Journal of Taxation, Estate Planning, Practical Tax Strategies and The Jerusalem Post. He is also frequently quoted by The New York Times, The Wall Street Journal, Daily Business Journal and Accounting Today. He also drafted legislation that passed the U.S. Congress declaring May as "National ALS Awareness Month."

Mr. Packman is active in the community; he is a member of the Kessenich Family MDA ALS Center Advisory Board and a past board member of the Easter Seal Society of Miami-Dade County and Israel Bonds organizations. While he has frequently been recognized for his volunteer efforts, Mr. Packman is proudest of having been the first recipient of the ALS Association's Kevin Packman Award for the Most Outstanding Volunteer.

Mr. Packman earned his B.A. in 1993 from the University of Texas (where he was named the Most Outstanding Individual in 1991), his J.D. in 1998 from Washington University School of Law (where he received the Honor Scholar award and in 2011 the Distinguished Young Law Alumni Award) and LL.M in Estate Planning in 2002 from the University of Miami School of Law (where he received the Vice President's Award for Service).

Quoted Articles

  • Daily Tax Report, "Wegelin Indictment Signals New Battleground In U.S. Offshore Evasion Fight, Attorneys Say," February 6, 2012
  • Associated Press, "Romney Offshore Accounts Contain Up to $32 Million," January 20, 2012
  • Accounting Today, "IRS Triple Play on Offshore Voluntary Disclosures," January 20, 2012
  • Bloomberg, "IRS Gives Another Chance to U.S. Citizens With Undeclared Assets," January 10, 2012
  • Daily Tax Report, "IRS Reopens Offshore Voluntary Disclosure Initiative, Says $4.4 Billion Collected So Far," January 10, 2012
  • The Wall Street Journal, "What's Next for Offshore Accounts?," December 10, 2011
  • Daily Tax Report, "Taxpayers Fear Disclosing Offshore Assets As Deadline Approaches, Practitioners Say," August 15, 2011
  • The Wall Street Journal, "Sacre Bleu! The Foreign-Account Penalty," April 30, 2011
  • Accounting Today, "Tax Practitioner Dangers from Voluntary Disclosures," March 11, 2011
  • Daily Business Review, "Clients Told to Rethink Taking IRS Amnesty Offer on Unreported Offshore Bank Accounts," September 27, 2010
  • CFO Zone, "IRS Employment Tax Audits Underway," September 21, 2010
  • Going Concern, IRS's Employment Tax National Research Project Just Getting Started, September 21, 2010
  • OnWallStreet.com, "The UBS Fallout," August 27, 2010
  • Automated Trader, "IRS Sees Withdrawing Case Against UBS This Fall," August 26, 2010
  • MoneyLaundering.com, "IRS Beefs Up International Tax Enforcement Effort with Reorganization, Increased Staffing," August 5, 2010
  • Broward-Palm Beach New Times, "Local Holocaust Survivors Find Pro-Bono Pension Help," July 26, 2010
  • Daily Business Review, "HSBC trying to avoid becoming next UBS," July 26, 2010
  • Jewish Journal, "Reaching Out to Survivors," June 30, 2010
  • Sun-Sentinel, "Former Nazi Slave Laborers Seek Payment from Germany," June 25, 2010
  • The Wall Street Journal, "IRS Faulted for Prosecuting Confessed Evaders of Taxes," May 5, 2010
  • Accounting Today, "Taxes Know No Borders," April 19, 2010
  • Daily Business Review, "Will New Tax Law Put Damper on Foreign Investments," April 7, 2010
  • The Wall Street Journal, "IRS Eases Squeeze on Some Foreign Account Holders," March 5, 2010
  • South Florida Sun-Sentinel.com, "IRS to Begin Audit Sweep on Employment Taxes," February 12, 2010
  • American Express Small Business Open Forum, "Hot to Deal with Audits," February 11, 2010
  • The New York Times, "Swiss Back Away From Deal to Give Names of Wealthy UBS Clients to U.S.," January 28, 2010
  • Hedge Fund Law Report, "Bills in Congress Post the Most Credible Threat to Date to the Continued Tax Treatment of Hedge Fund Performance Allocations as Capital Gains," December 30, 2009
  • The American Lawyer, "A Very Big Net – Holocaust Survivors Are Caught in the UBS Tax Probe," November 2009
  • The Wall Street Journal, "Tax Evaders Face Money-Laundering Rules," October 22, 2009
  • The Wall Street Journal, "New Era to Confess A Secret Bank Account," October 20, 2009
  • Investment News, "Offshore Banking on Endangered List," August 24, 2009
  • Investment News, "IRS on UBS Tax Evasion Settlement: We've Only Just Begun," August 19, 2009
  • The Wall Street Journal, "Tax Cheat Showdown: Fees Up or Stay Quiet?," August 14, 2009
  • The Wall Street Journal, "Switzerland, UBS Settle U.S. Tax Case," August 13, 2009
  • Daily Business Review, "Swiss, U.S. Reach Agreement in UBS Tax Evasion Dispute," August 13, 2009
  • The Wall Street Journal, "Tax Evaders Flock to IRS To Confess Their Sins," July 30, 2009
  • Daily Business Review, "DOJ-UBS Compromise May Pry Loose Names of Biggest Tax Cheats," July 14, 2009
  • Business Week, "The New Global Hunt for Tax Cheats," May 27, 2008
  • The New York Times, "I.R.S. Seeks Reports of Foreign Account," May 16, 2008

Community Involvement

  • Holland & Knight LLP, Miami Pro Bono Co-Chair, 2009-Present
  • Miami Children's Hospital, Ambassador Legacy Board, 2009-Present, and Chair, 2011-2012
  • University of Miami Planned Giving Advisory Board, Member, 2008-Present
  • Greater Miami Jewish Federation, Professional Advisory Committee, Lunch & Learn Co Chair, 2007-2009; Chair, 2010-2011
  • ALS Recovery Fund President, 2001-2009, and Chairman/CEO, 2010-Present

Professional Honors & Awards

  • Top Up and Comer, South Florida Legal Guide, Tax, Estate Planning, 2011
  • Chambers USA – America's Leading Business Lawyers guide, Tax: Estate Planning, 2011
  • Top 40 Under 40, South Florida Business Journal, 2011
  • Distinguished Young Law Alumni Award, Washington University Law, 2011
  • Most Effective Pro Bono Lawyer, Daily Business Review, 2011
  • Florida Legal Elite, Florida Trend magazine, 2010-2011
  • Rising Star, Florida Super Lawyers magazine, 2009-2011
  • Thelma Gibson Community Service Award, 2010
  • Up and Comer Finalist, South Florida Business Journal
  • Florida Legal Elite "Up & Comer," Florida Trend Magazine, 2005-2007
  • Dorothy Shula Award for Outstanding Volunteerism Finalist, United Way of Miami-Dade, 2006
  • 100 "A" List Floridians, Florida International Magazine, 2005
  • Health Care Hero Award, Greater Miami Chamber of Commerce, 2002
  • Martindale-Hubbell AV Rated

Memberships

  • AICPA International Tax Technical Resource Panel's Foreign Trust (Form 3520) Task Force, Member, 2011-Present
  • AICPA International Tax Technical Resource Panel's Foreign Bank and Financial Accounts Reporting (FBAR) Task Force, Member, 2009-Present
  • Society of Trust and Estate Practitioners (STEP), Member, 2009-Present
  • ABA - Real Property, Probate and Trust Law Section, 2002-Present; Tax Litigation and Controversy Section, Co-Vice Chair, 2010-2012
  • ABA Tax Section, 2002-Present
  • The Florida Bar - Tax Law Section, 2002-Present; Civil Tax Procedure, Chair, 2008-2009; International Trusts & Estates, Vice Chair, 2011-2012
  • The Florida Bar - Real Property, Probate and Trust Law Section, 2002-Present
  • Dade County Bar Association - Probate & Guardianship Committee, 2002-Present

Court Admissions

  • U.S. Tax Court

Speaking Engagements

  • "The FBAR Regulations are Now Final – The FATCA – Reporting is Coming – A Survival Guide for CPA’s and Attorneys," FICPA and Florida Bar International Tax Conference, January 19, 2012
  • "FATCA IRC 6038D New IRS Form 8938 – More Than FBAR," International Law International Tax Committee Teleconference, January 24, 2012
  • "Report of Foreign Bank and Financial Accounts Update," AFP Annual Conference, Roundtable, November 8, 2011
  • "Cutting-Edge Developments With Respect to Tax Fraud and Collection Considerations as Related to International Tax," International Income Tax and Estate Planning 2011, The Florida Bar CLE Committee and the International Law Section, October 27, 2011
  • "FBAR and FATCA – Reporting Foreign Financial Accounts," AICPA International Business Conference, June 14-15, 2011
  • "2011 Voluntary Offshore Disclosure Program," The Tax Section of The Florida Bar, June 8, 2011
  • "International Tax Enforcement in Era of Transparency – A Technical Update for Practitioners and Institutional Service Providers," Annual STEP Pacific Rim Conference, May 12-13, 2011
  • "Report of Foreign Bank and Financial Accounts: Preparing for 2011 Filings," Strafford Publications, Inc., May 4, 2011
  • "Implications of the IRS Offshore Voluntary Disclosure Program," Offshore Alert Conference, April 6, 2011
  • "2011 Offshore Voluntary Disclosure Initiative (OVDI) and Update on Report of Foreign Bank and Financial Accounts (FBAR) Guidance," ABA 2011 Offshore Voluntary Disclosure Initiative Teleconference, March 16, 2011
  • "U.S. Residence, Domicile and Situs: Considerations for International Clients," Holland & Knight Institute Videoconference, January 19, 2011
  • "The Tightening Noose of International Tax Compliance for U.S. Taxpayers," Suncoast Estate Planning Council - November Roundtable, November 11, 2010
  • "International Tax Compliance and Transparency – A Whole New World," NYU Institute on Federal Taxation, October 22, 2010 (NYC) and November 19, 2010 (San Diego)
  • "International Tax Update," Holland & Knight Institute Videoconference, February 17, 2010
  • "Estate Planning with Intellectual Property," Holland & Knight Institute Videoconference, November 18, 2009
  • "Ethical Issues in Offshore Tax Evasion: UBS and Beyond, The Center for Ethics and Public Service," University of Miami School of Law, November 4, 2009
  • "Offshore Compliance Initiative," ABA Income & Transfer Tax Planning Committee, International Tax Planning Committee Conference Call, June 25, 2009
  • "Flagship Tax Investigations - UBS, Credit Suisse, HSBC and LGT Bank: An Analysis & Update," Annual Offshore Alert Conference, April 28, 2009
  • "Trusts and Confidentiality: The End of the Banking Secrecy?," ABA International Section, April 17, 2009
  • "Pre-Immigration Planning and Ethical Issues in Representing the Foreign Individual," New York University Summer Institute in Taxation, July 14, 2008
  • "New Return Preparer Rules - The Standards, The Penalties," Northern Trust Legal Series, March 11, 2008
  • "International Estate Planning and Compliance: Complex Issues and Practical Solutions for the Practitioner," Annual All Children's Hospital Tax, Legal and Financial Planning Seminar, February 13, 2008
  • "Forms over Substance: An Overview of International Tax Compliance Requirements," Bnai Brith, November 9, 2007
  • "Potpourri of International Tax Compliance Issues and Update on Expatriation," International Income Tax and Estate Planning, Florida Bar, October 12, 2007
  • "FBAR - What You Need To Know/Why You Should Care," ABA Section of Taxation and Section of Real Property, Probate & Trust Law -- Joint Fall CLE Meeting, September 28, 2007
  • "FBAR - What You Need To Know/Why You Should Care," Florida Bar Ullman Year In Review, June 30, 2007
  • "FBAR - What You Need To Know/Why You Should Care," HK Tax Controversies Seminar, June 15, 2007

Published Articles & Books