With a global tax practice at Legamaro Banipal LLP, Michael J. Legamaro provides international income, capital, estate, inheritance and gift tax-planning and implementation solutions for ultra-high-net-worth clients, their investment vehicles and related structures – principally those who are globally active, hold concentrated wealth with multi-jurisdictional assets, business and reach, and are acting for their own accounts or are the foreign financial institutions catering to and advising such wealth. In that regard, he provides individually tailored, holistic and creative solutions to the problems faced by multi-jurisdictional and multi-generational families, and the private banks and investment advisers assisting them, whether based in the United States, Asia, Europe, Latin America or elsewhere. Michael frequently works with foreign attorneys and the clients' internal or external advisors to assist in the formulation of an international strategy or the implementation of an international solution. These solutions involve the coordination of cross-border tax issues and address concerns regarding the location of the client's assets or their family members.
More generally, Michael assists foreign and domestic corporations (both public and private), partnerships and real estate investment trusts, wealthy and entrepreneurially-minded individuals, and trusts in the analysis, structuring and negotiation of corporate and real estate transactions, leveraged buyouts, reorganizations, debt restructuring, consolidation and similar transactions, as well as planning for the creation, preservation and transmission of wealth among generations. In addition, Michael has developed significant experience in tax and business strategies and other acquisition/disposition transactions for large and small real estate portfolios, owners and developers, including multibillion-dollar real estate investment trusts and real estate partnerships, as well as strategic business planning across the globe. He is a frequent speaker and lecturer at international tax or private wealth conferences worldwide.
In addition to his current practice, Michael served as former chair of the Global Private Client practice at DLA Piper LLP, the world’s largest law firm. There, he coordinated the activities of scores of DLA Piper's lawyers across the globe who advise clients with regard to their respective home country and international income, estate, capital duty, succession tax and business planning needs and oversee implementation of those plans. In addition, he coordinated tax advice for the firm’s client’s needing assistance with respect to their more domestic United States tax planning and implementation issues.
Michael's experience includes the following:
● Planning and implementation in connection with a billion-dollar plus mixed use high-rise, ultra-luxury hotel, condominium development on New York City’s Central Park South on behalf of a billionaire Malaysian family where the project promises to become NYC’s most exclusive residential development
● Inbound planning for global families acquiring oil and gas, commercial real estate and other business interests in the United States with a view toward creative reduction of overall tax
● Developing and implementing synthetic structures designed to achieve business and tax efficiencies similar to a spinoff of unwanted assets or subsidiaries when more traditional spinoff structures are unavailable
● Planning and implementation of complicated like-kind exchange programs
● Development and implementation of creative tax-oriented techniques designed to take publicly traded professional services companies private using leveraged employee stock ownership plans
● Development and implementation of creative techniques involving tax-wise charitable giving, family limited partnerships, and limited liability companies, and techniques designed to reduce the imposition of US estate, gift and generation-skipping taxes
● Formation, operation and merger advisory services (both buy side and sell side) advice for large and small financial institutions, including banks, hedge funds, and private equity funds, in which one, several or all of the elements at issue are not based in the United States
In 2010, Michael was ranked in National Tier 1 for a Private Funds/Hedge Funds Law practice by The Best Lawyers in America.
● J.D., Northwestern University School of Law (1986) Executive Editor, Journal of Criminal Law & Criminology
● A.B., Washington University in St. Louis (1983), summa cum laude, Phi Beta Kappa, Omicron Delta Kappa, Mortar Board Memberships
● Society of Trusts & Estates Practitioners, Chicago Branch (Chairman Emeritus)
● Transnational Tax Network (Executive Committee Member Emeritus)