Mr. Jaramillo advises multinational corporations, financial institutions, and individual clients on a broad range of tax matters, including tax controversies, risk management and international compliance, and cross-border structuring. He also utilizes his Spanish fluency to advise Spanish-speaking clients.
Mr. Jaramillo's major areas of practice include subpart F, tax treaty issues and competent authority proceedings, FATCA entity classification and compliance, withholding and information reporting, financial products, and individual compliance.
Mr. Jaramillo also advises on the international tax issues of high-net-worth clients with respect to pre-immigration and structuring cross-border investments. He has extensive experience advising both U.S. taxpayers and individuals living abroad with undisclosed foreign assets on U.S. tax compliance issues, especially those with foreign business and trust interests.
During law school, Mr. Jaramillo served as an extern in the Small Business/Self-Employed Division at the IRS's Office of Chief Counsel. Before joining Caplin & Drysdale, he practiced in the tax group of a major international law firm.
- Speaker, Opportunity Zones, Latino Tax Fest, August 1, 2019
- Chair, Digital Economy Roundtable Discussion, 12th Annual U.S. and Latin America Tax Practice Trends Conference, June 14, 2019
- Moderator, Global Trends with Respect to Withholding Taxes, IBA Annual Conference Rome 2018, October 10, 2018
- Panelist, Global Trends in Transparency and Disclosure, American Bar Association, 2018 Fall Tax Meeting, October 5, 2018
- Panelist, Inbound Financing After Tax Reform - What Now?, American Bar Association, 2018 Fall Tax Meeting, October 4, 2018
- Speaker, Narrowing the Gap: Does the New Tax Law Materially Mitigate International Tax Planning Incentives for U.S. MNCs, National Association for Business Economics, 8th Annual NABE Transfer Pricing Symposium, July 18, 2018
- Speaker, U.S. Tax Reform, International Tax Commission of the Mexican Institute of Public Accountants (IMCP), February 14, 2018
- Speaker, Perspectives on U.S. Tax Reform and Its Implications for Companies Established in Mexico, Sustainable Development Secretariat of the State of Queretaro, February 13, 2018
- Panelist, Perspectives on U.S. Tax Reform, COPARMEX Queretaro, February 13, 2018
- Speaker, Exchange of Information Argentina-United States, Torcuato Di Tella University, August 24, 2017
- Speaker, U.S. Tax Obligations of International Clients (English Session), Latino Tax Professionals Association, 2017 National Convention, August 10, 2017
- Speaker, U.S. Tax Obligations of International Clients (Spanish Session), Latino Tax Professionals Association, 2017 National Convention, August 9, 2017
- Panelist, Tax Controversy Roundtable: Where Have All the Good Guys Gone!, 10th Annual U.S. - Latin America Tax Planning Strategies, June 15, 2017
- Panelist, International Information Reporting, 2017 ABA Section of Taxation May Meeting, May 13, 2017
- Speaker, Panel was entirely in Spanish: Alternative Solutions of Disputes in Tax Matters: Arbitration, APAs Transfer, Mutual Agreements and Concluding Agreements, ANEFAC Monterrey Magno Evento Anual, October 28, 2016
- Speaker, Voluntary Disclosure Programs: Recent Developments & How Long Will They Last, University of San Diego School of Law - Procopio International Tax Institute Conference, October 21, 2016
- Speaker, FATCA's Expanding Global Reach: A Concern for Big and Small, ABA Tax Section, January 29, 2016
- Speaker, Cumplimiento Internacional, FBARs, y mas (Presentation in Spanish), Latino Tax Professionals Association, 2015 National Convention, August 5, 2015
- International Compliance, FBARs, and More, Latino Tax Professionals Association, 2015 National Convention, August 4, 2015
- Speaker, The Implications of FATCA in Switzerland, University of Geneva, Tax Law Day, February 2, 2015
Click here for a full list of speaking engagements.
- "Decrypting The New IRS Cryptocurrency Compliance Letters,"
with Zhanna A. Ziering, Law360 Tax Authority, August 7, 2019
- "Cryptocurrency Criminal Tax Cases Coming Soon,"
with Zhanna A. Ziering, Mark E. Matthews, and Scott D. Michel, Caplin & Drysdale Client Alert, July 23, 2019
- "Combating Aggressive Tax Planning Through Disclosure: A Comparison of U.S. and EU Rules Applicable to Tax Advisors,"
ABA Tax Times, June 14, 2019
- "Tax Problems Loom in the College Admissions Scandal,"
with Meghan R. Biss, Alison F. Egan, and Moshe A. Dlott , Caplin & Drysdale Client Alert, March 18, 2019
- "When Opportunity Knocks: Qualified Opportunity Zone Proposed Regulations Released,"
with Jonathan S. Brenner, Caplin & Drysdale Client Alert, October 22, 2018
- "EXPERT ANALYSIS: U.S. Owners of Foreign Trusts Face Increased IRS Scrutiny,"
Law360, June 21, 2018
- "IRS Adds Foreign Trust Information Reporting to Compliance Campaign Program,"
with Kirsten Burmester, Dianne C. Mehany, and Anne J. O'Brien, Caplin & Drysdale Client Alert, June 1, 2018
(republished in Global Tax Weekly)
- "IRS to Revoke Passports for Seriously Delinquent Tax Debts Starting February 2018,"
with Dianne C. Mehany, Zhanna A. Ziering, Mark D. Allison, and Christopher S. Rizek, Caplin & Drysdale Client Alert, February 12, 2018
- "Possible Tax Fallout for Student and Professional Athletes from NCAA-Related Investigations,"
with Scott D. Michel and Mark D. Allison, Caplin & Drysdale Client Alert, November 9, 2017
- "Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets,"
with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Kirsten Burmester, Caplin & Drysdale Client Alert, November 6, 2017
- "U.S. Passports in Jeopardy for Taxpayers Owing the IRS,"
with Niles A. Elber, Dianne C. Mehany, and Zhanna A. Ziering, Caplin & Drysdale Client Alert, December 9, 2015
- "Me, Myself, and My Subsidiary: A Shift in the Intent Standard in Related-Party Hybrid Debt Cases,"
with Stafford Smiley, Corporate Taxation, September 1, 2013
- "Case Updates-Dell Products (Norway) General Electric Capital (Canada) SNF (Australia),"
with Stafford Smiley, Corporate Taxation, March 1, 2012
Click here for a full list of publications.
