David J. Berardo
Unique International Experiences
Education:
Pomona College, Claremont, California
B.A., International Relations, 1964
UCLA School of Law, Westwood, California
J.D., 1967
Unique International Experiences:
Accounting & Tax Practice: Partner in Charge of Los Angeles office of an international accounting firm responsible for international tax consulting and compliance.
Asset Protection: Domestic and international asset protection, including formation and management of foreign and domestic trusts, corporations, and partnerships. Repatriate foreign assets, earnings and accumulations to the US and transfer US assets to foreign persons.
Foreign Tax Planning: Structure investment by foreign persons in US commercial ventures; portfolio loan from foreign lenders to generate tax free US source income, free from US withholding; form foreign captive insurance companies; worldwide exploitation of intellectual property from the US; structure formation of companies and trusts in Ireland, UK, Switzerland, Saudi Arabia, Samoa, Hong Kong, Singapore, Cayman Islands, Cook Islands, Liechtenstein, Anguilla, Bermuda and British Virgin Islands for asset protection and other business purposes; and capture of foreign trading profits and commissions abroad by US persons in companies which are not controlled foreign corporations.
China Practice: Represent China State Enterprises doing business in the US: capitalize California import/export subsidiaries; secure visas and extensions; advise on transfer pricing agreements; resolve customs disputes; and general advice on doing business in US. Represent US companies manufacturing in Hong Kong and PRC: intercompany pricing; repatriation of foreign earnings by subsidiary under approved joint ventures and under sub contract arrangements; restructure ownership for 1997 Hong Kong take over; and conversion of joint venture to contract manufacturing.
Charitable and Exempt Organization Practice: Organize and manage domestic and international exempt organizations. Design and implement various international charitable donations of cash and appreciated property, including publicly traded securities. Design and implement international charitable annuities.
Domestic Tax Planning: Partnership syndication to domestic and foreign persons to raise capital for US investment; design and implement merger of companies with net operating loss carry forwards; restructure partnership interests involving substantial debt forgiveness; portfolio debt borrowings from foreign lenders; corporate reorganizations; domestic estate planning; and domestic asset protection.
Estate Planning: Assist foreign persons with assets in the US transfer those assets to appropriate US and foreign entities to avoid US estate tax. Design and implement appropriate US and foreign legal structures, such as domestic and foreign trusts and family partnerships.
Foreign Corporate Reorganization: Reorganize companies in Saudi Arabia, Luxembourg, Liechtenstein, Lebanon, Netherlands Antilles, New Zealand, Hong Kong and United Kingdom.
Foreign Insurance Transactions: Design and implement privately placed casualty, annuity and life insurance contacts with foreign insurer.
Mergers & Acquisitions: Design and implement taxable and tax-free reorganizations, recapitalizations, mergers and acquisitions with domestic and foreign targets and acquirers.
Mexico Practice: Establish Maquildora operations for furniture and apparel manufacturers; finance waste recycling facility in Mexico by secured loans from Mexican and US lenders, including FSC equipment leasing. Design and implement estate plans for Mexican citizens with assets in the US and for US citizens with assets in Mexico.
Saudi Arabia Practice: Resident legal officer for various commercial enterprises, including representation and joint venture document preparation.
Trust Administration: Serve as trustee of domestic and foreign trusts.
Other Activities:
NASD Arbitrator: 1997 to present
Resident England: 1977-1982
Resident Saudi Arabia: 1974
Resident Germany: 1963
Resident Austria: 1959
Professor, United States Estate & Gift Taxation: 1969
Current International Projects
Inbound and Outbound: From Thought to Finish
Descriptions Available upon Request
