Flávia Allegro Gerola joined the firm in 2011. Flávia is a senior associate of the Tax Group, focusing her practice in the Wealth Management area, tax planning and tax controversy.
Flavia worked as a foreign associate in the Chicago Office (2016) and in the Miami Office (2017) of Baker & McKenzie LLP, in the Tax Group and focusing her practice with the Wealth Management group.
Awards and Recognitions
In 2020, Flávia was named "Rising Star" in the Wealth Management area by Legal 500. In 2018, Flávia was awarded in the Thesis Competition of STEP Latam Conference, held in México City, for her article "The Use of Trusts and Fideicomissos in Latim America Jurisdictions".
Flávia obtained her LL.M. (Masters of Laws) degree and Wealth Planner certificate from Northwestern University Pritzker School of Law (Chicago, 2016). Post Graduate Degree in Tax Law from Pontificia Universidade Católica de São Paulo (2012). Graduated from Pontificia Universidade Católica de São Paulo (2010).
Activities outside the office
Flávia was an Assistant Professor in the post graduation courses of Estate Planning and Taxation of Income and Services at Fundação Getúlio Vargas (Direito GV) from 2013 to 2015.
Speaker in the Wealth Management panel of "12th Annual U.S. and Latim America Tax Practice Trends Conference - American Bar Association" (June of 2019, Miami - USA).
1. "Gift Tax consequences between Spouses of Different Citizenships". Probate and Property Magazine - A publication of Real Estate, Trust and Estate Law Section ABA American Bar Association (2017)
2. "Regularização, no Regime Especial de Regularização Cambial e Tributária, de estruturas fiduciárias no exterior (Trusts) e offshores": NEDER, Marcos Vinicius; GEROLA, Flávia Allegro. Regularização, no Regime Especial de Regularização Cambial e Tributária, de estruturas fiduciárias no exterior (trusts) e offshores. In: Instituto Brasileiro de Estudos Tributários, et al. (Org.). PRODIREITO: Direito Tributário: Programa de Atualização em Direito: Ciclo 3. Porto Alegre: Artmed Panamericana; 2017. p. 99-132. (Sistema de Educação Continuada a Distância, v. 2)
3. "The Use of Trusts and Fideicomissos in Latim America Jurisdictions". Article awarded in the STEP Latam Conference, in October of 2018 (México City, México).
4. "A responsabilidade tributária das holdings familiares nos planejamentos sucessórios" em Co-autoria com Maria Rita Ferragut. Published at Conjur in 24.06.2020. https://www.conjur.com.br/2020-jun-24/feragut-gerola-holdings-familiares-planejamentos-sucessorios
5. "O tratamento tributário das partnerships (estruturas flow through) no Brasil" : NEDER, Marcos Vinicius; GEROLA, Flávia Allegro. Temas atuais em tributação internacional – Brasil 2020. São Paulo: Trench, Rossi e Watanabe Advogados. ISBN: 978-65-992030-0-8.
6. "Planejamento tributário e sucessório com ativos financeiros no exterior" co-authored with Thales Stucky. Published at JOTA in 13.10.2020. https://www.jota.info/opiniao-e-analise/colunas/coluna-do-carf/planejamento-tributario-ativos-financeiros-exterior-13102020
Portuguese and English
Representative matters and clients
Flávia's focuses her practice on Wealth Management and international clients, their families and family offices. Flávia assist her clients structuring their inbound and outbound investments. Her practice includes: international estate planning, structuring real estate holding structures and Family holdings companies, preimmigration planning, expatriation planning, global exchange of information (FATCA, CRS), and other international tax planning matters. She also handles general tax planning and administrative tax litigation.
Latin America: Updates on Wealth Tax in...
In brief The COVID-19 pandemic, together with populist politics, political instability, and public health and security concerns, has increased the number of bills of law aimed at addressing taxation of significant amounts of revenues, commonly known as Wealth Tax. We are facing a trend among Latin American jurisdictions to propose and in some cases to […]
News and deadlines for submitting Indiv...
Brazilian taxpayers can already submit their Declaration of Foreign Assets to Brazilian Central Bank (the so called “DCBE”), which is due on April 5, 2021. The declaration shall be filed by individuals or legal entities resident, domiciled or headquartered in Brazil, with foreign assets in the amount equal to or greater than: (i) USD 1.000.000.00 […]
Changes on the Transfer Tax – ITC...
On August 13th, Legislative Bill nº 529/2020 (“Bill 529/20”) was published, proposing changes on the transfer tax (“ITCMD”) legislation in the State of Sao Paulo. The purpose is to equalize the deficit from the negative effects of the COVID-19 pandemic on public revenue and recover part of the State’s investment capacity. The main changes addressed […]