Practices

Taxation
International and Cross Border Transactions

Education

University of Florida Levin College of Law, J.D., with honors

University of Florida College of Law, LL.M., with high honors, Taxation

University of Miami, MBA, with honors

University of Miami, B.A., with high honors, International Finance and Marketing

Bar Admissions

Florida

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Summer Ayers LePree

Associate
Miami
t: 305-789-7609

Summer Ayers LePree focuses her practice in the area of domestic and international taxation. Ms. LePree has been involved in tax planning relating to sophisticated international and domestic restructurings, joint ventures, mergers and acquisitions, terminations, liquidations, and other domestic and international tax matters, both inbound and outbound. She also has experience providing private wealth services to high-net-worth individuals with cross-border issues, including extensive experience with expatriation and pre-immigration planning. In addition, Ms. LePree represents clients before the Internal Revenue Service and the United States Tax Court.

Professional Honors & Awards

  • American Bar Association, Tax Section, Nolan Fellow, 2010-2011
  • Richard B. Stephens Award, Outstanding L.L.M. Tax Graduate, University of Florida Levin College of Law

Memberships

  • American Bar Association, Tax Section
  • American Bar Association, USAFTT Committee, FDAP Subcommittee, Chair
  • International Bar Association, Tax Section
  • The Florida Bar, Tax Section

Speaking Engagements

  • "U.S. International Tax Planning in the Cloud," ABA Tax Section Meeting, Washington, D.C., May 11, 2012
  • "Computing the Gain from the Sale of CFC Shares Under Section 1248," CITE U.S. International Tax Reporting and Compliance, Ft. Lauderdale, FL, February 7, 2012
  • "Tax Planning for and Ethical Issues in Representing the Foreign Individual Investing in or Moving to the U.S.," NYU Summer Institute in Taxation, New York, NY, July 11, 2011
  • "Joint International Developments," ABA Tax Section Meeting, Washington, D.C., May 6, 2011
  • "Coming and Going Part II: Focus on Going: Exit Strategies for the Private Client. Is Getting Up and Going a Good Solution?" International Bar Association (IBA) Annual Conference, Vancouver, Canada, October 3-8, 2010
  • "Expatriation Under Section 877A's Mark-To-Market System, and What Notice 2009-85 Did and Did Not Tell Us," ABA Joint Fall Meeting, Toronto, Canada, September 24, 2010
  • "Pre-Immigration Planning and Ethical Issues in Representing the Foreign Individual," NYU Summer Institute in Taxation, New York, NY, July 19, 2010
  • "Understanding the U.S. International Tax System," CITE Introduction to U.S. International Tax Seminar, Coral Gables, FL, January 25, 2010
  • "New Section 7874 Regulations," ABA Tax Section Meeting, Chicago, IL, September 2009
  • "Pre-Immigration Planning and Ethical Issues in Representing the Foreign Individual," NYU Summer Institute in Taxation, New York, NY, July 13, 2009
  • "Expatriate Games," ABA Tax Section Meeting, New Orleans, LA, January 9, 2009

Published Articles & Books

  • "New Temporary and Proposed Regulations Attack Some Cross-Border Equity-Swap Payments," Journal of Taxation, April 2012
  • "U.S. Tax Planning for the International Transportation of Goods by Containers," Florida Bar Journal, Vol. 85, No. 10, December 2011
  • "U.S. Tax Planning for the International Transportation of Goods by Containers," Tax Notes International, Vol. 64, No. 8, November 21, 2011
  • "Tax Court Finds Variable Prepaid Forward Contract Gives Rise to Current Sale," Journal of Taxation, January 2011
  • "Understanding Key Provisions of the Tax Bill Passed By the Senate," Business and Tax, Alert - December 16, 2010
  • "Will Guarantee Fees Be the New Management Fees After Container Corp.?," WG&L Journal of Taxation, June 2010
  • "IRS Provides Guidance on Expatriation Exit Tax," Journal of Taxation, March 2010
  • "IRS Announces Intention to Require Reporting of Uncertain Tax Positions by Certain Business Entities," Business and Tax, Alert - January 29, 2010
  • "New Section 7874 Regulations Continue the Service's Attack on Inversion Transactions," Journal of Taxation, September 2009
  • "Final Regulations on Gain Recognition Agreements Provide Added Flexibility," Journal of Taxation, July 2009
  • "IRS Takes Flawed Approach to Inclusion Under Subpart F," Tax Notes, Vol.123, May 2009
  • "IRS Announces Reduced-Penalty Program for Taxpayers Who Voluntarily Disclose Offshore Accounts," Business and Tax, Alert - March 31, 2009
  • "NOL Carryback Period Extended to Five Years for Eligible Small Businesses," Business and Tax, Alert - March 24, 2009
  • "Taxation of United States Tax-Exempt Entities' Offshore Hedge Fund Investments: Application of the Section 514 Debt-Financed Rules to Leveraged Hedge Funds and Derivatives and the Case for Equalization," The Tax Lawyer, Vol. 61, No. 3, Spring 2008