Summer represents businesses and their owners in a variety of transactional tax matters, with a particular focus on international planning and transactions. Her practice is focused on advising U.S. and foreign-based private and public companies in connection with their inbound and outbound US international tax planning. She constantly monitors developments in the U.S. and global tax laws, and thoughtfully advises clients on the relevant implications to their businesses. Summer is a frequent speaker and author on a variety of cross-border income tax issues.
Professional Affiliations
- Member - The Florida Bar, Tax Section
- American Bar Association, Tax Section - Council Director, 2020-2023; Nominating Committee, 2023-2026
Education
- Master of Laws (LL.M.), Taxation, University of Florida (high honors)
- Juris Doctor (J.D.), University of Florida (honors)
- Master of Business Administration (M.B.A.), University of Miami (honors)
- Bachelor of Arts (B.A.), Univeristy of Miami (high honors)
Representative Matters
Some of the experience represented below may have been handled at a previous firm.
- Assisted with restructuring of global private equity fund, where majority interests are held by US citizens living in France, to maximize global tax efficiency. Guided specific cross-border tax planning for sale of certain current holdings.
- Represented real estate development company with structuring substantial outbound investments into Barbadian real estate. Later represented the 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 income realization and repatriation.
- Restructured entities to avoid currency restrictions in Belize, in order to facilitate partial sale of craft beer company to global brand and distributor and advised on US tax resulting from the restructuring and sale.
- 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 to minimize the fund’s US tax burden.
- Assisted a 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.
- 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 associated income, including impact of intereststripping limitations and deduction of accrued but unpaid interest.
Selected Speaking Engagements
- What the General Practitioner needs to know about Foreign Planning
- International Tax Developments (Inbound)
- An Epidemic of CFCs: Implications of the Repeal of Section 958(b)(4)
- Impact of Tax Reform on Cross-Border Sale of a Business
- Cross-Border Individual Matters
- International Tax Planning After the 2017 Act for Closely Held Businesses
- Outbound Tax Planning for Closely Held Businesses After the Tax Reform Act
- Section 962 in Cross-Border Tax Planning
- Cross-Border Individual Matters
- Advising U.S. Clients on Outbound Structuring
- International Taxation: What You Need to Know
- The Impact of U.S. Tax Reform on Inbound and Outbound U.S. Income Tax Planning
- Tax Reform: The Good, The Bad, and The Ugly
- Tax Treaties in Inbound Tax Planning
- Pre-Immigration Planning
- Funding Structures and Instruments: Re-Characterization of Debt into Equity
Honors & Recognition
- Lawdragon—Listed among the ”500 Leading Global Tax Lawyers” (2025)
- Chambers USA (Florida)—Recognized for Tax—“Up & Coming” (2017–2018); “Band 3” (2019–2022); and “Band 2” (2023–2026)
- The Best Lawyers in America—Named “Lawyer of the Year” (2021) and a “Leading Individual” for Tax Law in Florida (2016–2026)
- Lawdragon 500—Listed among the “500 Leading Dealmakers in America” (2025 and 2026)
- Florida Super Lawyers—Recognized (2020-2026) and named a “Florida Rising Star” (2017–2019)
- Miami Daily Business Review—Recognized as a “Rising Star” (2015)
- American Bar Association—Nolan Fellowship, Section of Taxation (2010)