International & Cross Border Transactions
Wealth Preservation & Estate Planning
Private Equity & Venture Capital
Daniel W. Hudson
Partner
Daniel W. Hudson is a Partner in the firm’s Miami office and a member of the firm’s Business, Finance & Tax Team and the International Tax Group.
Daniel frequently advises high net worth individuals, family offices, trust companies, private equity funds, as well as multinational corporations on addressing a variety of the US and cross-border business-related issues and international tax, trust, and succession planning issues. With a concentration on international taxation and business planning, Daniel’s practice includes (i) advising US and foreign individuals regarding design and implementation of cross-border business structures, acquisitions and joint ventures; (ii) addressing US federal and state tax (including treaty-related) issues for foreign clients investing or doing business in the US, especially with regard to inbound investments in US real estate and other issues involving the Foreign Investment in Real Property Tax Act (FIRPTA); (iii) advising foreign individuals who are considering immigrating or temporarily moving to the US and families with one or more members who are US citizens or are currently residing in the US; (iv) advising US individuals and corporations on structuring of foreign businesses and investments; (v) assisting US and foreign clients with US tax compliance and regularization issues (both federal and state); (vi) assisting US client with expatriation tax planning; and (vii) addressing trust and estate law, as well as any ancillary tax issues, in relation to US and foreign trusts and estates and cross-border families.
As a tax practitioner, Daniel represents taxpayers before the Internal Revenue Service in connection with audits, IRS Appeals, installment agreements, offers in compromise, penalty abatements, offshore voluntary disclosures, and other administrative matters. Daniel also represents businesses before the Florida Department of Revenue in relation to sales and use tax and corporate tax issues, as well as voluntary disclosures and workouts.
Representative Matters 
- Assisted Swiss exhibition company with establishing US structure in relation to their annual art fair on Miami Beach.
- Provided tax and corporate advice to Hungarian software company on migration of parent company to the United States through a reverse merger, transferring of relevant intellectual property, and addressing transfer pricing issues in relation to intercompany research & development and service agreements.
- Provided tax and corporate advice to Brazilian company in the oil & gas industry, which included establishing structure to mitigate U.S. effectively connected income through use of Netherlands structure.
- Advised ultra-high net worth Mexican client on establishing and maintaining efficient tax and corporate structure for investment in U.S. real property, taking into consideration U.S. income, gift and estate tax implications.
- Advised ultra-high net worth Brazilian client on establishing and maintaining efficient tax and corporate structure for investment in U.S. real property, taking into consideration U.S. income, gift and estate tax implications.
- Advised ultra-high net worth Colombian client on international tax, trust and estate planning for family which included U.S. beneficiary children and grandchildren.
- Advised Swiss company on the establishment of U.S. subsidiary blocker structure for U.S. portion of international art fair to mitigate U.S. federal income taxes, and included advice on transfer pricing issues relating to intercompany licensing and provision of services.
- Advised estate of high net worth Mexican decedent on the decanting of New Zealand trust to the United States for the U.S. beneficiaries in order to mitigate against potentially punitive U.S. tax rules relating to foreign non-grantor trusts.
- Advised high net worth Brazilian client on pre-immigration planning to mitigate U.S. federal income, gift and estate taxes prior to relocation to the United States.
- Advised group of Costa Rican high net worth clientele on establishing and maintaining efficient tax and corporate structure for investment in U.S. real property.
- Advised group of Lebanese and Swiss clientele on the establishment of U.S. operational structure for international restaurant business, incorporating the use of portfolio debt.
Awards & Honors
- The Best Lawyers in America®, 2024-2026
Community Activities / Associations
- Exit Planning Institute (Miami) - Founding Member
- American Bar Association - Member
- Society of Trust and Estate Practitioners (STEP) – Member
- Florida Bar Tax Section - Assistant Director of Section Administration
- Greater Miami Tax Institute - Member
- International Tax Group (Miami) – Member
- Florida International Bankers Association (FIBA) - Member
In the News
Fifty-Six Berger Singerman Attorneys Recognized in the 2025 Edition of Best Lawyers In America
August 15, 2024
March 12, 2024
November 9, 2021
January 15, 2021
Law360 "Berger Singerman Adds Ex-Payless CLO, Baker McKenzie Atty"
January 15, 2021
Events & Speaking Engagements
February 7, 2024
May 9, 2022
February 18, 2022
April 30, 2021
March 5, 2019
July 24, 2018
March 23, 2017
Daniel W. Hudson, Co-presenter, "Foreign Investment in US Real Estate," STEP Presentation
March 16, 2016
October 16, 2015
October 16, 2015
October 15, 2015
January 8, 2015
Doing Business in Florida Blog
March 6, 2024
November 30, 2023
October 18, 2023
Prior Affiliations
- Baker McKenzie