Guillermo J. Fernández-Quincoces is of counsel and a tax lawyer with Foley & Lardner LLP. Guillermo focuses his substantial practice on estate and trust planning and administration, business tax and transactional practice, charitable planning and giving, international transactions and taxation, and tax-exempt entities and charitable organizations. He is a member of the Taxation, Transactional & Securities, International, Latin America, and Estates & Trusts Practices.
Guillermo’s experience includes representing clients in restructuring life insurance planning, estate tax audits, family estate planning transactions involving complex valuation issues, private letter ruling requests before the IRS involving complex estate, gift and generation-skipping tax issues, private letter rulings on the tax effects of abandoning U.S. permanent resident's visa, probate court proceedings involving the reformation, acceptance and removal of trusts and trustees. He has represented clients in international and general tax law (inbound and outbound U.S. tax planning), commercial law, international cross-border transactions, as well as purchasers in governmental privatizations. Guillermo has also represented high-net-worth U.S. and non-U.S. citizens in connection with domestic and international estate planning and wealth preservation, including asset protection, income, gift, estate and generation-skipping tax planning, probate and estate administration, trust administration, prenuptial agreements and pre-immigration income and estate planning and off-shore trust planning. He has experience establishing tax efficient offshore trusts with U.S. and foreign beneficiaries. Some of these trusts have been audited by the IRS field personnel and were the subject of a favorable technical advice memorandum by the IRS National Office as well as establishing complex Dutch, and U.K.-based structures for both international clients and U.S. companies seeking treaty benefits, preparing and obtaining favorable private letter rulings on "portfolio debt" issues. Guillermo has acted as the lead attorney in a nine-figure merger among a number of companies that were privately held by one client, and a publicly listed REIT. He has represented Fortune 100 companies (in the foodstuffs and leisure industries) in setting up operations in each of the major countries in South America, selection of tax and entity structure of the operations in each of the applicable countries and coordination of such structuring with local counsel and in-house tax departments and/or general counsel. He also has a working knowledge of aspects of civil law in various South American countries. He has acted as tax and general counsel for a local cigarette manufacturer and its majority stockholder as well. He is currently working with Mexican counsel on formulating the most tax efficient manner for the nine figure recapitalization of the debt of a Mexican entity.
Guillermo received his law degree from Boston University (J.D., 1977). He graduated from Harvard University (M.B.A., 1974), and received his bachelor’s degree from St. Peters College (B.S., 1970).
Guillermo is a member of the Cuban American CPA Association; the Coral Gables and Greater Miami Chamber of Commerce; the Planned Giving Council of Dade County; and the board of directors of the Dade Community Foundation.
In 2010 - 2012, the U.S. Legal 500 recognized Guillermo for his work in the area of tax. He has been Peer Review Rated as AV Preeminent®, the highest performance rating in Martindale-Hubbell® Peer Review Ratings™ system. He was honored as a Top Lawyer since the 2006 edition of the South Florida Legal Guide, and in 2006, 2007, 2008 and 2009, he was selected for inclusion in the Florida Super Lawyers® lists. He was also selected by his peers for inclusion in The Best Lawyers in America© since 2008 in the field of tax law.
Admissions and Professional Memberships
Guillermo is admitted to practice in Florida and United States Tax Court. He is a member of the Dade County Bar Association; the International Tax Committee, Florida State Bar Association; Taxation Section, the American Bar Association; the Florida Association of Attorney-Certified Public Accountants; the Cuban American Certified Public Accountants Association; the Florida Institute of Certified Public Accountants; Legal Services of Greater Miami, Inc.; and is a member of the board of directors of Bacardi, Ltd., the largest privately owned spirits company in the world.
He is fluent in Spanish and is also a certified public accountant.