Jennifer Migliori

Partner

  • Jennifer Migliori
  • Phone: +1 305 960 2235

    Import to Address Book

  • Duane Morris LLP
    201 S. Biscayne Boulevard, Suite 3400
    Miami, FL 33131-4325
    USA

Jennifer A. Migliori is a partner in Duane Morris' Corporate Practice Group and practices in the areas of international taxation, wealth preservation planning and private equity transactions. Ms. Migliori has experience developing and implementing tax-efficient investment structures. She has developed a focus on complex international corporate structures, trust planning, and compliance. Ms. Migliori also regularly advises clients on various tax matters including international information sharing arrangements, tax treaties, the Foreign Account Tax Compliance Act (FATCA), expatriation, pre-immigration tax planning, and tax controversy matters including audit representation and voluntary disclosures. Ms. Migliori is vice-chair of the firm’s Private Equity Division within the Corporate Practice Group.

Ms. Migliori represents investors, fund managers, family offices, financial institutions, fiduciaries, high-net-worth individuals and owners of closely-held companies.

Ms. Migliori is admitted to practice law in Florida and Pennsylvania, and before the U.S. Tax Court. Ms. Migliori earned her LL.M. in Taxation from the New York University School of Law and her law degree from University of Virginia School of Law, where she was Editor-in-Chief of the Virginia Tax Review. She is a graduate of the Florida Fellows Institute of the American College of Trust and Estate Counsel (ACTEC).

Ms. Migliori is fluent in English and Spanish.

Areas of Practice

  • Strategic Tax Planning
  • Wealth Transfer Planning

  • Private Equity

Representative Matters

  • Represented high-net-worth family in connection with cross-border tax planning, redomiciled trust and domesticated foreign corporations after some members of the family relocated to the United States.

  • Assisted with the creation of a non-resident trust to hold foreign assets for the benefit of U.S. beneficiaries of Mexican family, further advised as to the U.S. tax consequences of U.S. resident beneficiaries.

  • Guided dozens of high-net-worth clients through IRS examinations and Foreign Bank Account Reporting compliance.

  • Represented U.S. citizen in avoiding criminal sanctions in an investigation by IRS special agents and attorneys from the United States Department of Justice.

  • Represented large technology company during IRS examination in connection with employment taxes and withholding taxes, and tax planning in connection with global restructuring of operations in order to minimize U.S. income tax exposure.

  • Guided International Trust Company in assessing its FATCA and U.S. tax compliance obligations with respect to U.S. beneficiaries.

  • Represented foreign developer of self-storage facilities in the acquisition of facility sites in the United States.

  • Represented out-of-state trust company in establishing Florida presence.

  • Represented Goldman Sachs Lending Partners in a $700 million Senior Secured First Lien Term Loan Facility and $50 million Senior Secured First Lien Revolving Facility together with other security, credit, hedging and financing, resulting in an aggregate principal financing estimated to be $1.1 billion, with funding to be used to restart an oil refinery in the U.S. Virgin Islands.

Admissions

  • Florida
  • Pennsylvania
  • U.S. Tax Court

Education

  • New York University School of Law, LL.M., Taxation, 2014
  • University of Virginia School of Law, J.D., 2013
    - Editor-in-Chief, Virginia Tax Review
  • University of Miami Herbert Business School, B.B.A., Accounting, magna cum laude, 2006

Experience

  • Duane Morris LLP
    - Partner
    - Associate
  • Carlton Fields Jorden Burt P.A.
    - Associate
  • Holland and Knight LLP
    - Associate

Professional Activities

  • Florida Bar
    - Tax Section, Assistant Director of the Education Committee
    - Real Property Probate and Trust Law Section
  • International Bar Association
    - Taxes Committee

Honors and Awards

  • Listed in The Best Lawyers in America, 2024
  • Named a 2023 On the Rise attorney by the Daily Business Review, 2023
  • Named to Best Lawyers "Ones to Watch," 2023

Selected Publications

Selected Speaking Engagements

  • Panelist, “Pre-Immigration Tax and U.S. Investment Planning: Foreign-Source Income, Establishing Tax Residency, EB-5, and More” Strafford CLE Webinar, January 18, 2024
  • Speaker, "Planning for LATAM High-Net-Worth Families and Businesses," Latin America Private Clients Services Event, Duane Morris LLP (New York), October 18, 2023

  • Co-Chair, “Challenges of structuring pre-migration planning for HNI and families”, The Next Era of Taxation Conference, International Bar Association Taxes Committee, September 22, 2023

  • Co-Chair, “Global Tax Roundtable – Structuring Investments in Fintechs and Start-Ups: Common Structures For Entry Of Investments And Exit Via PPMs or IPOs”, The International Bar Association Annual Conference, Taxes Committee, Miami, November 2, 2022

  • Panelist, “Tax Transparency and Social Responsibility – Managing Opportunities and Risks of Ever Complex Tax Laws,” The Next Era of Taxation Conference, International Bar Association Taxes Committee, December 3, 2021

  • Speaker, Tax Issues in Cannabis and Commercial Real Estate, 6th Annual NAI Florida & Caribbean Conference, November 14, 2019

  • Panelist, "Helping International Clients Invest in the U.S. and Stay," Financial Planning Association of Miami Practice Management Breakfast, May 22, 2019

  • Panelist, Latin America & Caribbean Session, 5th Annual NAI Florida Conference, November 15, 2018

  • Presenter, "Cross-Border Tax and Wealth Planning," FY International Annual Summit Miami 2017, August 24, 2017
  • Speaker, "Pre-immigration Tax Planning Strategies," Leumi Third Annual Private Bank Investment Conference, December 5, 2016
  • Speaker, "FATCA and the Common Reporting Standard, Planning for Non-U.S. Persons," Pan-American Private Client Life Professional Development Workshop, May 23, 2016