Kevin E. Packman

Kevin E. Packman is an attorney in Holland & Knight's Private Wealth Services Group. He leads the firm's International Estate Planning Group as well as the Tax Controversy and Litigation Team. Mr. Packman's practice includes advising high-net-worth private clients (whether U.S. or foreign) with tax, trusts and estates. This also includes pre-immigration planning and expatriation planning. He also helps clients come into compliance and resolve tax controversies. He represents clients daily before the Internal Revenue Service (IRS) and has represented clients before the U.S. Tax Court. Mr. Packman is a fellow of the American College of Trusts & Estates (ACTEC), is a frequent writer and regularly speaks at national and international tax conferences. He is also frequently quoted by the national media.

The Chambers High Net Worth guide has recognized Mr. Packman since 2016 for Private Wealth Law: Florida, and his client work is widely recognized.

Kevin is a truly excellent lawyer, technically brilliant and extremely user-friendly. … He is great, an example of a broader lawyer, terrific lawyer, focused with clients in foreign accounts.

– Chambers High Net Worth 2022 guide

He is very effective, he is very organised and very thorough. He is also very detail-oriented.

– Chambers High Net Worth 2021 guide

Mr. Packman has experience:

• advising clients on Foreign Bank Account Reporting compliance
• guiding clients through IRS examinations and audits
• assisting domestic clients with preparation of estate plans to minimize gift and estate tax exposure
• creating structures through which international clients may invest in the U.S., and avoid estate tax exposure
• providing pre-immigration planning to foreign individuals planning to establish domicile in the U.S.
• advising U.S. beneficiaries of foreign trusts and/or estates on alternatives to reduce U.S. taxes

Additionally, Mr. Packman has:

• represented a non-resident alien in a criminal investigation by the United States Department of Justice resulting in no criminal charges being filed against the client
• negotiated the release of an IRS levy against a non-resident alien client's investment account
• resolved an IRS dispute with exposure in excess of $6 million involving income tax, gift tax and various penalty issues for failure to file Forms 3520 and 3520-A for $1.1 million
• represented a client in avoiding criminal sanctions in an investigation by IRS special agents and attorneys from the United States Department of Justice

Mr. Packman has lectured for the AICPA, ABA, New York University, University of Miami, The Florida Bar and STEP. He has also presented to numerous national and community institutions/organizations. Mr. Packman is a prolific writer with articles appearing in a number of publications, including The Florida Bar Journal, Journal of Accountancy, Journal of Taxation, Estate Planning, Practical Tax Strategies and The Jerusalem Post. He is also frequently quoted by The New York Times, The Wall Street Journal, Daily Business Journal and Accounting Today. He also drafted legislation that passed the U.S. Congress declaring May as "National ALS Awareness Month."

Mr. Packman is active in the community; he is a member of the Kessenich Family MDA ALS Center Advisory Board and a past board member of the Easter Seal Society of Miami-Dade County and Israel Bonds organizations. While he has frequently been recognized for his volunteer efforts, Mr. Packman is proudest of having been the first recipient of the ALS Association's Kevin Packman Award for the Most Outstanding Volunteer.

Mr. Packman earned his B.A. in 1993 from the University of Texas (where he was named the Most Outstanding Individual in 1991), his J.D. in 1998 from Washington University School of Law (where he received the Honor Scholar award and in 2011 the Distinguished Young Law Alumni Award) and LL.M in Estate Planning in 2002 from the University of Miami School of Law (where he received the Vice President's Award for Service).

Quoted Articles

• Law360, "5th Circ. Ruling For IRS Could Create Privilege Concerns," January 8, 2021
• Law360, "Microsoft Ruling Highlights Need to Document Biz Decisions," January 30, 2020
• Tax Notes, "CRS Data Breached in Bulgarian Tax Agency Hack," August 30, 2019
• Tax Notes, "John Doe Summonses Authorized for Finnish Residents' Bank Info," May 2, 2019
• Mansion Global, "How Do I Avoid Paying Double Taxes on Adjacent Plots of Land?," September 7, 2017
• Daily Tax Report, "Offshore Account Holders Lose Bid for Tax Penalty-Free Program," July 14, 2017
• Tax Notes, "Approval of Dutch Summons Request Could Soften U.S. Image," April 10, 2017
• Mansion Global, "What Are Some Last-Minute U.S. Tax Deductions for My Home?," April 6, 2017
• Mansion Global, "What Are the Tax Implications If I Buy a Property Under My Child's Name?," December 22, 2016
• Mansion Global, "What Are the Biggest Tax Concerns When Investing in London's Volatile Market?," December 15, 2016
• South Florida Legal Guide, "Trends in International Tax and Wealth Management," 2016
• Daily Business Review, "Tax Attorneys See Reason for Clients to Worry About Panama Papers," April 19, 2016
• Law360, "4 Tips On Filing Delinquent Int'l Tax Information Returns," March 23, 2016
• Tax Analysts, "Reporting Rule Might Deflect Some Criticism of U.S. as Tax Haven," February 1, 2016
• Daily Tax Report, "Law Yanking, Denying Passports for Tax Delinquency Criticized," December 14, 2015
• Tax Notes, "German State Pays €5 Million for Tax Data on Dividend Stripping," November 3, 2015
• Fox News, Special Report with Bret Baier, "Sharing Sensitive Information with the IRS," October 7, 2015
• The Wall Street Journal, "IRS Begins Sending Individual Account Information to Foreign Countries," October 2, 2015
• Tax Analysts, "Money From Egg Donation Is Taxable Compensation, Court Holds," January 23, 2015
• Daily Business Review, "Feds Were "Outlawyered" in UBS Case, Experts Say," November 4, 2014
• Daily Business Review, "Fort Lauderdale Trial Aims to Topple Top Level of Secret Bank Accounts," October 22, 2014
• Daily Tax Report, "IRS Plan to Deactivate Unused ITINs May Put Some With Legitimate Needs in Bind," July 16, 2014
• Daily Tax Report, "U.S. Taxpayers Abroad Could Become Compliant Under New Disclosure Program," June 3, 2014
• Daily Tax Report, "Jury Rules Zwerner Willfully Failed to File FBARs; Judge to Determine Penalties," May 28, 2014  
• Daily Tax Report, "Sen. Levin Sets New Hearing on Offshore Evasion; GAO Reports on Voluntary Disclosure," February 19, 2014
• Institutional Investor, "Family Offices, Wealth Managers Face New and Looming Tax Changes," February 19, 2014 
• Daily Tax Report, "Crackdown to Continue on Foreign Banks Helping Taxpayers Hide Assets, Attorneys Say," January 27, 2014
• Bloomberg Law, "Swiss Banks Under Pressure as Deadline Nears for DOJ Program to Find U.S. Accounts," December 20, 2013
• Daily Tax Report, "Nonresident Alien Brings Quest for Refund Of Improper Withholdings to Supreme Court," November 13, 2013 
• Daily Tax Report, "DOJ Program Lets Swiss Banks Reveal U.S. Account Information, Avoid Prosecution," August 30, 2013 
• The Jerusalem Post, "Finance: The US Taxman Cometh to Israel, with a Vengeance," August 22, 2013
• Daily Tax Report, "Conviction of Foreign Account Signatory For Tax Evasion Affirmed by Seventh Circuit," August 19, 2013
• The Wall Street Journal, "Overseas Americans: Time to Say 'Bye' to Uncle Sam?" August 17, 2013
• Bloomberg BNA, "U.S. Courts Allow IRS to Seeks Bank Card User Information at Norway's Request," July 31, 2013
• Bloomberg BNA, "Liechtenstein Bank Agrees to Pay $23.8 Million in Pact on Hidden Assets," July 31, 2013
• Tax Analysts, "DOJ Using John Doe Summonses to Collect Information on Behalf of Norway," July 30, 2013
• Tax Analysts, "FBAR E-Filing Rule Complicates Offshore Compliance," July 29, 2013
• Daily Tax Report, "Cayman Islands Unveils New Plan To Crack Down on Tax Evasion," June 25, 2013
• Heartlander Magazine, "Around Much of the World, U.S. is Considered a Tax Haven," June 3, 2013
• AccountingWeb, "IRS Announces Plan to Share Tax Data with Brits and Aussies," May 13, 2013
• Daily Tax Report, "U.S., U.K., Australia Teaming Up to Battle Offshore Tax Evasion, IRS Announces," May 10, 2013
• Daily Tax Report, "John Doe Summons to Wells Fargo Result Of IRS Data-Mining OVDPs, Practitioners Say," May 6, 2013
• Daily Tax Report, "Dozens With Bank Leumi Accounts Rejected From OVDP After Acceptance, Attorney Says," March 12, 2013
• Daily Tax Report, "'Kawashima' Raises Deportation Threat for Noncitizens Subject to U.S. Tax Laws," December 8, 2012
• CBS Miami, "Tax Refund Fraud Victims Getting Left Behind," October 17, 2012
• Daily Business Review, "Justice Watch: Feds Get Lift Against Offshore Holders," August 13, 2012
• The Wall Street Journal, "Israeli Tax Preparers Snared," June 17, 2012
• Daily Tax Report, "IRS Updates Questions and Answers for Reporting Foreign Assets on Form 8938, June 11, 2012
• Daily Tax Report, "FBAR, Form 8938 Filing Requirements Leading to Confusion, Some Practitioners Say," May 30, 2012
• CNBC, "Chasing Saverin's Winnings Is a Losing Battle," May 17, 2012
• The Wall Street Journal, "Facebook Co-Founder Fires Back at Senators' Accusations," May 17, 2012
• The Wall Street Journal, "Lawmakers Take Aim at Facebook Co-Founder Saverin," May 17, 2012
• Florida Trend, "Payback for Holocaust Survivors," May 9, 2012
• Daily Tax Report, "Wegelin Indictment Signals New Battleground In U.S. Offshore Evasion Fight, Attorneys Say," February 6, 2012
• Associated Press, "Romney Offshore Accounts Contain Up to $32 Million," January 20, 2012
• Accounting Today, "IRS Triple Play on Offshore Voluntary Disclosures," January 20, 2012
• Bloomberg, "IRS Gives Another Chance to U.S. Citizens With Undeclared Assets," January 10, 2012
• Daily Tax Report, "IRS Reopens Offshore Voluntary Disclosure Initiative, Says $4.4 Billion Collected So Far," January 10, 2012
• The Wall Street Journal, "What's Next for Offshore Accounts?," December 10, 2011
• Daily Tax Report, "Taxpayers Fear Disclosing Offshore Assets As Deadline Approaches, Practitioners Say," August 15, 2011
• The Wall Street Journal, "Sacre Bleu! The Foreign-Account Penalty," April 30, 2011
• Accounting Today, "Tax Practitioner Dangers from Voluntary Disclosures," March 11, 2011
• Daily Business Review, "Clients Told to Rethink Taking IRS Amnesty Offer on Unreported Offshore Bank Accounts," September 27, 2010
• CFO Zone, "IRS Employment Tax Audits Underway," September 21, 2010
• Going Concern, IRS's Employment Tax National Research Project Just Getting Started, September 21, 2010
• OnWallStreet.com, "The UBS Fallout," August 27, 2010
• Automated Trader, "IRS Sees Withdrawing Case Against UBS This Fall," August 26, 2010
• MoneyLaundering.com, "IRS Beefs Up International Tax Enforcement Effort with Reorganization, Increased Staffing," August 5, 2010
• Broward-Palm Beach New Times, "Local Holocaust Survivors Find Pro-Bono Pension Help," July 26, 2010
• Daily Business Review, "HSBC trying to avoid becoming next UBS," July 26, 2010
• Jewish Journal, "Reaching Out to Survivors," June 30, 2010
• Sun-Sentinel, "Former Nazi Slave Laborers Seek Payment from Germany," June 25, 2010
• The Wall Street Journal, "IRS Faulted for Prosecuting Confessed Evaders of Taxes," May 5, 2010 
• Accounting Today, "Taxes Know No Borders," April 19, 2010
• Daily Business Review, "Will New Tax Law Put Damper on Foreign Investments," April 7, 2010
• The Wall Street Journal, "IRS Eases Squeeze on Some Foreign Account Holders," March 5, 2010
• South Florida Sun-Sentinel.com, "IRS to Begin Audit Sweep on Employment Taxes," February 12, 2010
• American Express Small Business Open Forum, "Hot to Deal with Audits," February 11, 2010
• The New York Times, "Swiss Back Away From Deal to Give Names of Wealthy UBS Clients to U.S.," January 28, 2010
• Hedge Fund Law Report, "Bills in Congress Post the Most Credible Threat to Date to the Continued Tax Treatment of Hedge Fund Performance Allocations as Capital Gains," December 30, 2009
• The American Lawyer, "A Very Big Net – Holocaust Survivors Are Caught in the UBS Tax Probe," November 2009
• The Wall Street Journal, "Tax Evaders Face Money-Laundering Rules," October 22, 2009
• The Wall Street Journal, "New Era to Confess A Secret Bank Account," October 20, 2009
• Investment News, "Offshore Banking on Endangered List," August 24, 2009
• Investment News, "IRS on UBS Tax Evasion Settlement: We've Only Just Begun," August 19, 2009
• The Wall Street Journal, "Tax Cheat Showdown: Fees Up or Stay Quiet?," August 14, 2009
• The Wall Street Journal, "Switzerland, UBS Settle U.S. Tax Case," August 13, 2009
• Daily Business Review, "Swiss, U.S. Reach Agreement in UBS Tax Evasion Dispute," August 13, 2009
• The Wall Street Journal, "Tax Evaders Flock to IRS To Confess Their Sins," July 30, 2009 
• Daily Business Review, "DOJ-UBS Compromise May Pry Loose Names of Biggest Tax Cheats," July 14, 2009
• Business Week, "The New Global Hunt for Tax Cheats," May 27, 2008
• The New York Times, "I.R.S. Seeks Reports of Foreign Account," May 16, 2008

Community Involvement

• Holland & Knight, Miami Pro Bono Co-Chair, 2009-present
• Dave & Mary Alper Jewish Community Center, Board of Directors
• University of Miami Planned Giving Advisory Board, Member, 2008-present
• ALS Recovery Fund President, 2001-2009, and Chairman/CEO, 2010-present
• National Institute of Health Rare Disease Clinical Research Network, Patient Advocacy Group