Professional Experience
Flávia concentrates her practice and coordinates the Wealth Management group, focusing on tax advice for individuals and Family Offices, domestic and international succession planning, structuring investments inside and outside Brazil, pre-immigration planning, expatriation and global information exchange. She also works with tax planning for legal entities and tax litigation.
Work abroad
Flavia worked as a foreign associate in the Chicago Office (2016) and in the Miami Office (2017) of Ablfs & McKfnzif LLP, in the Tax Group and focusing her practice in the Wealth Management group.
Awards and Recognitions
In 2024, Flavia was recognized as “Rising Star Associate of the Year” by the prestigious ranking The Legal 500.
In 2021, 2022 and 2023, Flávia was recognized as a Star Associate and Associate to Watch by Chambers & Partners in the area of Private Wealth Law. Clients highlight her expertise in international succession planning and her dedication to her clients:
The clients recognize her as: “‘absolutely a rising star in the Brazilian Market’ remarks a source, adding: ‘She is completely dedicated to clients and she is extremely detail oriented. If you need someone to look at everything on a matter, Flávia is your lawyer. She is super technical, very methodical and has a real eye for detail.’ Sources also praise her experience handling tax and succession planning matters for high net worth clients.”
In 2022, 2021 and 2020, Flávia was named “Rising Star” in the Wealth Management area by Legal 500. The clients indicated that: “Flavia Gerola listens very well, asks the poignant questions and established amazing rapport with clients. Her international experience, cultural and language skills separate her from her peers/competitors“.
In 2022 and 2023 Flávia was also recognized by Leaders League in the Wealth Management area.
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”.
Academic Background
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
Member of STEP – Society of Trust and Estate Practitioners;
Member of the Study Group “Income Taxation in the XXI Century” at Fundação Getúlio Vargas (Direito FGV).
Flávia was an Assistant Professor in the post-graduation courses of Estate Planning and Taxation of Income and Services at Fundação Getúlio Vargas (Direito FGV) from 2013 to 2015.
Flávia is a speaker in several events with highlight to:
– “12th Annual U.S. and Latim America Tax Practice Trends Conference – American Bar Association” in the Wealth Management panel of American Bar Association Tax Conference in Miami – EUA, July 2019.
– “Tax Planning for Cross-border Families with a Focus on LatAm and Spain” organized by STEP USA e STEP Miami, February 2021;
– “Painel – Investimentos e Estruturas Societárias no Exterior” at IV Congresso Paranaense de Direito Empresarial – OAB/PR, October of 2021;
– International Private Client Conference – IPCC – in the panel “Private Client International Tax Updates Around the World”, event organized by IPCC in Miami, USA, May of 2023;
– Tax and Trust Conference, organized by Ablfs & McKfnzif, from 2016 to 2022, New York and Miami, EUA;
Publications
Flávia has several publications with highlight to:
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. Regularization, in the Special Regime for Foreign Exchange and Tax Regularization, of fiduciary structures abroad (trusts) and 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. (Distance Continuing Education System, 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
7. “Regimes de atração de ‘high-net-worth individuals’ e planejamento patrimonial para mudança de residência fiscal”: NOBREGA, Luciana; GEROLA, Flávia Allegro. In: Planejamento Patrimonial e Sucessório. Belo Horizonte: Editora Dialética, 2021.
8. “How Brazilian Usufructs Can Be Used for Wealth Planning”: DEPASQUALE, Paul; GEROLA, Flávia Allegro. Bloomberg Tax, 2023. https://news.bloombergtax.com/tax-management-international/how-brazilian-usufructs-can-be-used-for-wealth-planning
9.”Tax Treatment of Trusts in Brazil”: DEPASQUALE, Paul; GEROLA, Flávia Allegro. Trust Quarterly Review of STEP – Advising Families Across Generation, 2023. https://www.step.org/tqr/tqr-september-2023
10.”El impacto de la reforma fiscal brasileña en las multinacionales y en los profesionales de la fiscalidad mundial”, MACHADO, Clarissa; GEROLA, Flávia Allegro. Published in Forbes Mexico, 2024.
11.”O enfoque ESG para family offices”, JABRA, Alexandre; GEROLA, Flávia Allegro. Published in Valor Econômico, 2024. https://valor.globo.com/financas/esg/artigo/o-enfoque-esg-para-os-family-offices.ghtml
12. “O tratamento fiscal dos trusts no Brasil sob a ótica do art. 10º da Lei 14.754/23” GEROLA, Flávia Allegro. In: Imposto de Renda da Pessoa Física sobre Offshores e outros bens. São Paulo: MP Editora Dialética, 2024.
Representative matters and clients
Flávia coordinates and focuses her practice on Wealth Management area and private 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.
Languages
Portuguese and english.
