International Taxation
"All of the lawyers there are extremely creative. They can interpret the law and apply it to different situations, and they do a great job of involving the client and keeping them informed."
- CHAMBERS USA source
Bilzin Sumberg’s International Tax & Private Wealth lawyers are recognized in CityWealth Magazine, Private Client Global Elite Directory, Chambers USA, and Chambers High Net Worth (HNW), the first of its kind international resource for family offices and professional wealth advisors. In 2024, the firm was ranked in Tier 1 of the Miami, Florida area for both the Tax Law and the Trusts & Estates sections of Best Law Firms (a ranking of Best Lawyers). Our attorneys work closely with high-net worth individuals and cross-border families in creating and implementing globally tax-efficient wealth transfer planning vehicles and structures for both inbound investments into the United States and outbound investments into non-U.S. countries. Wealth transfer planning for our clients typically centers on the implementation of a trust vehicle to pass wealth from one generation to the next. Our team also assists clients with pre-immigration planning in anticipation of moving to the United States, whether on a temporary or permanent basis. For non-U.S. clients looking to make investments in the United States, our attorneys assist with tax structuring to achieve favorable U.S. tax outcomes in relation to investments ranging from pure passive holdings to active trades or businesses. Our outbound planning involves the minimization of local country taxation, the deferral of income earned outside of the United States, foreign tax credit planning, and the efficient repatriation of profits to the United States.
EXPERIENCE
Structured and negotiated license and royalty arrangements in Europe and Central and South America.
Representation of international investment securities brokerage in connection with an IRS tax controversy regarding withholding taxes.
Advised Israeli technology fund on its plans to introduce Israeli technology into the South American market. Various Israeli companies, with innovative products ranging from cyber-attack prevention to quick-acting paving sealants to virtual health care, will license their technologies to the fund, w...
Representation of Brazilian trademark licensing company in its tax structuring.
Assisted with the restructuring of a family-owned and family-run global private equity fund, where two-thirds of the family lives in France (some are U.S. citizens), and one third resides in the U.S., to maximize global tax efficiency in light of U.S. tax reform law. Guided specific cross-border tax...
Restructured entities to avoid currency restrictions in Belize to facilitate partial sale of a domestic beer company to a global brand and distributor. Advised on minimizing U.S. tax resulting from the restructuring and sale to defer U.S. recognition of the gain from the sale. Additional restructuri...
INSIGHTS
The IRS has finalized long-awaited regulations under Internal Revenue Code §2801 and released a draft of Form 708, which U.S. beneficiaries must use to report certain gifts or bequests from former U.S. citizens or Green Card holders ("covered expatriates"). These transfers may be subject to a 4...
Shawn Wolf moderates Market Pulse: National Economic & Capital Markets Briefing for STEP Miami’s June webinar. The panel discusses recent government insights on monetary policy, capital market controversies, and trade dynamics.
Ryan J. Coyle serves as a panelist for the International Bar Association’s webinar titled “Migrating the family business: the tax and succession pitfalls.” The panel discusses minimizing tax liabilities, addressing inheritance laws and ensuring compliance across jurisdictions when ...
Ryan J. Coyle moderates Global Spotlight Session 2: Brazil, Chile and Italy at Bilzin Sumberg’s 8th Annual International Tax & Wealth Planning Conference. This panel covers the most important considerations for cross-border tax and estate planning for Brazilian, Chilean, and Italian indivi...
Ryan J. Coyle serves as a guest speaker on the podcast “UK USA” where he discusses the unique challenges faced by LGBTQ families protecting their assets in an international context.
Alex Denault serves as a speaker for the STEP Miami webinar entitled “Concierge Healthcare for Global Families,” where he discusses the legal and tax issues for global families in planning for their healthcare needs.
Related Practices