Ronald E. Evans

Biography

Ronald Evans is managing partner in Venezuela, and chairs the Firm's Global Wealth Management practice group as well as the Tax Practice in Venezuela. He represents Latin America in the Firm's Tax Policy Group, and is highly recommended by various legal directories. He was the first chief of the Venezuelan tax administration’s (SENIAT) international affairs division, and served as Venezuela’s official negotiator for double taxation treaties from 1994 to1996.

Ronald was an advisor to the minister of foreign affairs on double taxation issues from 1997 to 1999. He has chaired the Venezuelan branch of the International Fiscal Association since 2007, and is a member of STEP’s Advisory Committee for Latin America.

Practice Focus

Ronald Evans joined the Firm in 1996 and became partner in 2002. He advises on the taxation of cross-border transactions and investments, including direct foreign investment, joint ventures, M&A, restructurings, transfer pricing, permanent establishments, tax treaties, wealth management and dispute resolution.

He has extensive litigation experience in Venezuelan tax courts and the Venezuelan Supreme Court, and has dealt with some of the largest assessments made by the Venezuelan tax administration.

Representative Legal Matters

Advised a large pharmaceutical group on the best corporate structure to expand the company's manufacturing business in Latin America.
Helped design and implement a corporate restructuring involving related foreign holding companies, with detailed analysis on the tax consequences arising from such restructuring.
Advised on the Venezuelan tax implications of a major worldwide spin-off involving the companies’ Venezuelan operations.

Professional Associations and Memberships

Venezuelan Finance Law Association - Member
Caracas Bar Association - Member
International Fiscal Association - Member
Italian Association for the Study of Latin American Tax Law - Member
Venezuelan Tax Association - Member

Admissions

Venezuela (1990)

Education

Universidad Monteavila (Diploma Hydrocarbon and Mining Law) (2007)
University Central de Venezuela (LLM Tax) (1996)
Harvard University (LLM) (1993)
Harvard University (Diploma International Tax Program) (1993)
University Central de Venezuela (JD) (1989)

Languages

English
French
Italian
Portuguese
Spanish

Author, “Litigation of Transfer Pricing Cases in Venezuela,” Transfer Pricing Litigation: Theory and Practice, Lexis-Nexis, 2008

Author, “Tax Treatment of Dividends under Double Taxation Agreements,” Studies on International Tax Law, Legis, 2006

Co-author, “Attribution of Profits to Permanent Establishments: An Analytical Approach,” IBFD (International Bureau of Fiscal Documentation), 2005

Author, “Worldwide Basis of Taxation: Determination of Worldwide Net Taxable Income, Foreign Source Losses and Imputation of Reign Taxes,” 60 Years of Venezuelan Income Taxation, Venezuelan Tax Law Association, 2003

Author, Régimen Jurídico de la Doble Tributación Internacional (Double Taxation Juridical Regime), McGraw-Hill, 1999