Ryan J. Coyle

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Area of Focus: Private Wealth Services, Tax
Ryan J. Coyle

Ryan J. Coyle focuses his practice on international tax matters, with an emphasis on providing tax-efficient restructuring solutions for high-net-worth international families and their closely held businesses. In addition to advising US-based families on income, gift, and estate tax matters, he assists non-US families with tax matters relating to pre-immigration planning and inbound investment.

Ryan also has extensive experience advising on outbound tax matters. This includes US anti-deferral legislation (i.e., Subpart F and GILTI) applicable to non-US entities that become controlled foreign corporations, oftentimes with regard to corporate clients that domesticate to the United States or individuals who become US tax residents while maintaining their structures outside the United States. In addition, he advises on planning related to tax treaty interpretation, expatriation, qualified small business stock (QSBS), and the Foreign Investment in Real Property Tax Act (FIRPTA). Ryan is experienced in international enforcement initiatives such as the Foreign Account Tax Compliance Act (FATCA), the Common Reporting Standard (CRS), and the Corporate Transparency Act (CTA). 

In conjunction with such planning, Ryan assists high-net-worth individuals in establishing complex trust structures and other vehicles to protect wealth and to efficiently transfer wealth from one generation to another. He advises family offices, as well, on the formation of private trust companies (“PTCs”) to serve as trustees of family trusts. Ryan is experienced in withholding obligations under Chapter 3 and Chapter 4 (FATCA), along with the associated forms from the W-8 series.

Having been based in London and Hong Kong at various points in his career, Ryan has unique insight into the needs of global clients and speaks extensively on topics related to international taxation.

Q & A
How are you unique from other tax lawyers?
An effective tax and private wealth lawyer should possess the broad skill set of a personal advisor, including legal acumen, cultural competency, and interpersonal abilities. Proficiency in international tax law is paramount, but a nuanced understanding of cross-cultural and family dynamics is also essential for servicing clients with diverse backgrounds and needs. Moreover, maintaining relationships with professionals across practice areas and industries is important, as client needs are often multifaceted and thus require multiple coordinated specialties. As a trilingual lawyer who has lived and worked abroad, I have prioritized these non-legal areas of my practice in order to differentiate myself from my peers. Ultimately, success as a tax lawyer hinges on fostering trust through personalized counsel and delivering tailored solutions aligned with clients' objectives.
What attracted you to practice at Bilzin Sumberg’s Tax & Private Wealth Group?
Bilzin Sumberg advises on highly complex matters and convenes practitioners who excel at tackling the most challenging legal issues. The firm’s Tax & Private Wealth Group is no exception. Its deep bench of experienced international tax practitioners prioritizes thought leadership, and emphasizes ongoing learning to effectively meet the evolving needs of its clients. This reputation attracts top-tier talent, which in turn allows me to better serve my clients.
  • Georgetown University, L.L.M., 2012
    Ohio State University, J.D., 2011
    Georgetown University, B.A., 2007
  • Brazilian-American Chamber of Commerce of Florida
    International Bar Association

    Co-Chair, LGBTQI+ Law Committee, 2024 - 2025
    Co-Vice Chair, LGBTQI+ Law Committee, 2023 - 2024
    Secretary, LGBTQI+ Law Committee, 2021 - 2022

    Society of Trust and Estate Practitioners (STEP)
  • District of Columbia
    New York
  • The National LGBTQ+ Bar Association, 40 Best LGBTQ+ Lawyers Under 40, 2024
    Latinvex, Latin America Rising Legal Star, 2022
  • Portuguese