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  1. Professionals

Summer A. LePree

Partner

Miami

+1 305-910-0540

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  • Overview
  • Experience
  • Credentials
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Summer represents businesses and their owners in a variety of transactional tax matters, with a particular focus on international planning and transactions.

Summer is a tax partner in the Miami office. 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 regularly assists clients with Subpart F, GILTI, and FDII planning, FIRPTA issues, treaty planning and analysis, and overall structuring for tax optimization.

Summer is a frequent speaker and author on a variety of cross-border income tax issues and, is actively involved in the ABA Tax Section, where she currently serves on the Council.

Key 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 in light of 2017 US tax reform law. 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 realization of GILTI after 2017 tax reform.
  •  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 interest-stripping limitations under Section163(j) on deductibility of interest after 2017 tax reform and deduction of accrued but unpaid interest pursuant to Section 267(a)(3).

  • 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” (2023–2024)
  • The Best Lawyers in America—Named “Lawyer of the Year” (2021) and a “Leading Individual” for Tax Law in Florida (2016–present)
  • Lawdragon 500—Listed among the “500 Leading Dealmakers in America” (2025)
  • Florida Super Lawyers—Recognized (2020) 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)

  • The Florida Bar, Tax Section
  • American Bar Association, Tax Section – Council Director, 2020-2023; Nominating Committee, 2023-2026
  • American College of Tax Counsel - Fellow

Capabilities

Tax
Mergers & Acquisitions

Key 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 in light of 2017 US tax reform law. 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 realization of GILTI after 2017 tax reform.
  •  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 interest-stripping limitations under Section163(j) on deductibility of interest after 2017 tax reform and deduction of accrued but unpaid interest pursuant to Section 267(a)(3).

Credentials

Education

Summer received her L.L.M. in Taxation with high honors and J.D. with honors from the University of Florida. She received her M.B.A with honors and B.A. with high honors from the University of Miami.

    Admissions
    • Florida

    Related Insights & News

    Publications & Speaking Engagements
    • Speaker, “What the General Practitioner needs to know about Foreign Planning,” 70th Annual Tulane Institute Conference, November 2022
    • Speaker, “International Tax Developments (Inbound),” 45th Annual Tax Law Conference, Federal Bar Association, March 2021
    • Speaker, “An Epidemic of CFCs: Implications of the Repeal of Section 958(b)(4),” Florida Tax Institute 2021 Conference, March 2021
    • Speaker, “Impact of Tax Reform on Cross-Border Sale of a Business,” 38th Annual Florida Bar/FICPA International Tax Conference, January 2020
    • Speaker, “Cross-Border Individual Matters,” GW Law’s 32nd Annual Institute on Current Issues in International Taxation, December 2019
    • Speaker, “International Tax Planning After the 2017 Act for Closely Held Businesses,” 68th Annual Tulane Tax Institute, November 2019
    • Chair, “Outbound Tax Planning for Closely Held Businesses After the Tax Reform Act,” Florida Tax Institute, February 2019
    • Speaker, “Section 962 in Cross-Border Tax Planning,” 37th Annual Florida Bar/FICPA International Tax Conference, January 2019
    • Chair, “Cross-Border Individual Matters,” GW Law’s 31st Annual Institute on Current Issues in International Taxation, December 2018
    • Speaker, “Advising U.S. Clients on Outbound Structuring,” University of Florida's Tax Course, July 2018
    • Speaker, “International Taxation: What You Need to Know,” New York University's International Taxation Conference, July 2018
    • Speaker, “The Impact of U.S. Tax Reform on Inbound and Outbound U.S. Income Tax Planning,” TerraLex, March 2018
    • Speaker, “Tax Reform: The Good, The Bad, and The Ugly,” iLaw2018: The ILS Global Forum on International Law, February 2018
    • Speaker, “Tax Treaties in Inbound Tax Planning,” Florida Tax Institute, March 2017
    • Speaker, “Pre-Immigration Planning,” International Fiscal Association - U.S. and Switzerland Branches, February 2017
    • Speaker, “Funding Structures and Instruments: Re-Characterization of Debt into Equity,” International Bar Association, November 2016
    Recognitions
    Winston Partners Featured on the Lawdragon 500 Leading Global Tax Lawyers List 2025

    May 19, 2025

    Recognitions
    Winston Partners Recognized on the 2025 Lawdragon 500 Leading Dealmakers in America List

    October 22, 2024

    Recognitions

    Winston Attorneys Recognized in The Best Lawyers in America® 2025

    August 15, 2024

    Recognitions
    Winston & Strawn Recognized in Chambers USA 2024

    June 6, 2024

    In the Media
    Jeffrey Rubinger and Summer LePree Join Winston in Miami

    July 21, 2023

    Press Release
    Winston & Strawn’s Miami Office Strengthens Corporate Practice With Addition of Tax Duo Jeffrey Rubinger and Summer LePree

    July 20, 2023

    View All Insights & News

    Capabilities

    Tax
    Mergers & Acquisitions
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