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.