Firm: Winston & Strawn LLP
Location: Miami - FL
-
200 S. Biscayne Boulevard
Miami, FL 33131
USA
- Tel : 305-910-0500
- Fax : N/A
- Email : slepree@winston.com
Summer represents businesses and their owners in a variety of transactional tax matters, with a particular focus on international planning and transactions.
Summer is a tax partner in the Miami office. Her practice is focused on advising U.S. and foreign-based private and public companies in connection with their inbound and outbound US international tax planning. She constantly monitors developments in the U.S. and global tax laws, and thoughtfully advises clients on the relevant implications to their businesses. Summer regularly assists clients with Subpart F, GILTI, and FDII planning, FIRPTA issues, treaty planning and analysis, and overall structuring for tax optimization.
Summer is a frequent speaker and author on a variety of cross-border income tax issues and, is actively involved in the ABA Tax Section, where she currently serves on the Council.
Recognitions
- Leading Individual, Tax Law, The Best Lawyers in America (Florida), 2016 – present
- Band 2, Tax, Chambers (2023) (Florida); Band 3, Tax, Chambers USA (Florida), 2019-2022
- Up & Coming, Tax, Chambers USA (Florida), 2017 – 2018
- Lawyer of the Year, Tax Law, The Best Lawyers in America (Florida), 2021
- Florida Super Lawyers, 2020
- Florida Rising Stars, Florida Super Lawyers 2017 – 2019
- Rising Star, Miami Daily Business Review, 2015
- Nolan Fellowship, American Bar Association, Section of Taxation, 2010
Activities
- The Florida Bar, Tax Section
- American Bar Association, Tax Section – Council Director, 2020-2023; Nominating Committee, 2023-2026
- American College of Tax Counsel – Fellow
Key Matters
Some of the experience represented below may have been handled at a previous firm.
- Assisted with restructuring of global private equity fund, where majority interests are held by US citizens living in France, to maximize global tax efficiency in light of 2017 US tax reform law. Guided specific cross-border tax planning for sale of certain current holdings.
- Represented real estate development company with structuring substantial outbound investments into Barbadian real estate. Later represented the company with restructuring such investments in connection with split-up transactions, including disposition and loss planning, basis transfer issues, and overall outbound restructuring for future realization of GILTI after 2017 tax reform.
- Restructured entities to avoid currency restrictions in Belize, in order to facilitate partial sale of craft beer company to global brand and distributor and advised on US tax resulting from the restructuring and sale.
- Advised on a cross-border structure for an investment fund of Chinese investors making inbound investments into US life settlement policies. The structuring utilized provisions of a US income tax treaty to minimize the fund’s US tax burden.
- Assisted a large technology and software company specializing in software services to global 1000 companies with restructuring global operations to minimize worldwide tax on income from US and foreign-source software sales.
- Advised inbound lending fund on season and sell structuring to minimize risk of US trade or business classification, and general inbound tax planning to minimize US taxation of associated income, including impact of interest-stripping limitations under Section163(j) on deductibility of interest after 2017 tax reform and deduction of accrued but unpaid interest pursuant to Section 267(a)(3).
Winston & Strawn LLP
With an international geographic reach, Winston & Strawn’s integrated tax practice addresses virtually all areas of tax law. Our group of 40 tax attorneys is well-versed in representing some of the largest public and privately-held corporations, exempt organizations, and large estates.
Our tax controversy attorneys provide clients with comprehensive coverage of tax dispute risks. Our extensive experience ranges from state and local to federal and international tax matters. We employ a pro-active approach that leverages litigation preparedness to maximize successful outcomes, whether through administrative resolution or at trial in all manner of litigation forums, including state, federal and appellate courts.
Our tax attorneys regularly partner with regional and international Winston practice areas to offer clients legal counsel in the areas of mergers and acquisitions, investments, and restructurings. Our financial tax attorneys represent major banks in connection with their operations in the United States, as well as significant domestic participants in the financial services industry, including hedge funds and private equity firms. Our insurance tax attorneys regularly represent domestic and multinational insurance companies on a wide variety of tax matters, including tax controversy and tax planning work. The experience of our insurance tax attorneys extends to all stages of the controversy lifecycle, including audit, appeals, and litigation, at both the state and federal levels, and the planning lifecycle, including acquisitions, restructurings, and product tax matters.
We have long distinguished ourselves in the tax advantaged financing area and assist developers as well as lenders. Our tax lawyers have extensive experience helping clients with alternative energy and other Congressionally authorized tax incentive programs. We also possess significant practices in federal tax planning and state and local tax planning.
Working closely with our tax attorneys, Winston’s trusts and estates attorneys provide counseling to individuals and corporate fiduciaries regarding estate and tax planning, estate and trust administration, and litigation. We also offer extensive experience in structuring and counseling charitable foundations on tax and corporate issues.
We have successfully assisted clients such as Fage International S.A., Lear Corporation, Nuveen Investments, Inc., Renaissance Technologies, Republic Services, Waste Management, and Yum! Brands. Within the energy industry, we represent EDF Renewable Energy and Invenergy, LLC. We also represent various financial institutions and banks, private equity firms, and hedge funds.