Summer LePree

Summer Ayers LePree

Partner
Baker & McKenzie LLP

Biography

Summer LePree is a partner in Baker McKenzie's Tax Practice Group. Summer is a go-to lawyer for clients who need sophisticated, creative, international tax counsel. Summer is a frequent speaker and author on a variety of cross-border income tax issues, is actively involved in the ABA Tax Section, where she currently serves as the Council Director for the International Committees, and teaches as an adjunct professor for the graduate tax programs at the University of Florida and the University of Miami Law Schools.

Practice Focus

Summer’s practice is focused on advising US and foreign-based public and private companies in connection with their inbound and outbound US international tax planning. She constantly monitors developments in US 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.

Representative Legal Matters

Prior to joining the Firm, Summer handled the following matters:

  • Assisted with the restructuring of a global private equity fund, where majority interests are held by US citizens living in France, to maximize global tax efficiency in light of US tax reform law. Guided specific cross-border tax planning for the sale of certain current holdings.

  • Represented real estate development company with structuring outbound investments of over USD 325 million into Barbadian real estate. Later represented 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.

  • Restructured entities to avoid currency restrictions in Belize to facilitate partial sale of a beer company to a global brand and distributor. Advised on minimizing US tax resulting from the restructuring and sale. Additional restructuring ensured the availability of foreign tax credits, which was otherwise uncertain based on certain Belize tax issues.

  • 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 that allowed the fund to avoid the US withholding tax of 30% of the gross amount on the income associated with the investments in the policies.

  • Assisted 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. Restructuring yielded substantial global tax savings.

  • 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 the associated income, including the impact of the interest-stripping limitations under Section 163(j) on the deductibility of interest after 2017 tax reform and the deduction of accrued but unpaid interest pursuant to Section 267(a)(3).

Professional Honors

  • Band 3, Tax, Chambers USA, 2019
  • Up & Coming, Tax, Chambers USA, 2017 - 2018
  • Leading Individual, Tax Law, The Best Lawyers in America, 2016 - 2020
  • Lawyer of the Year, Tax Law, The Best Lawyers in America, 2021
  • Florida Super Lawyers, 2020, Florida Rising Stars, Florida Super Lawyers 2017 - 2019
  • Rising Star, Daily Business Review, 2015
  • Nolan Fellowship, American Bar Association, Section of Taxation, 2010

Professional Associations and Memberships

  • The Florida Bar, Tax Section
  • American Bar Association, Tax Section - Council Director, 2020-2023
  • International Bar Association - US National Reporter, Taxes Committee 2014 - 2015, Member

Admissions

  • Florida~United States (2006)

Education

  • University of Florida (LLM Taxation with high honors) (2007)
  • University of Florida (JD with honors) (2006)
  • University of Miami (MBA with honors) (2003)
  • University of Miami (BA with high honors) (2002)

Languages

  • English
  • Speaker, “Impact of Tax Reform on Cross-Border Sale of a Business,” 38th Annual Florida Bar/FICPA International Tax Conference, January 2020

  • Speaker, “Cross-Border Individual Matters,” GW Law’s 32nd Annual Institute on Current Issues in International Taxation, December 2019

  • Speaker, “International Tax Planning After the 2017 Act for Closely-Held Businesses,” 68th Annual Tulane Tax Institute, November 2019

  • Chair, “Outbound Tax Planning For Closely-Held Businesses After the Tax Reform Act,” Florida Tax Institute, February 2019

  • Speaker, "Section 962 in Cross-Border Tax Planning," 37th Annual Florida Bar/FICPA International Tax Conference, January 2019