Richard S. Levine

Special counsel | New Haven, New York

Richard is special counsel in the private client and tax team.

He is familiar with the taxation of partnerships, LLCs, corporations and trusts from both an income and an estate tax perspective, along with knowing how to incorporate them into international structures, he is one of our renaissance lawyers who ties together many aspects of our tax practice for individuals and wealthy families. Richard recently helped a real estate developer transfer minority interests in closely-held entities to trusts to minimize both state income tax and federal estate taxes; a hedge fund manager form a private trust company to administer both personal and charitable assets; a wealthy entrepreneur to create an insurance dedicated fund as part of US pre-immigration planning; and an investment professional to expatriate while minimizing his exit tax. When he is not using private placement insurance and annuity structures to confound the IRS, he is busy confounding opponents decades his junior by blowing up their tanks in late night games of Battlefield on his son’s Xbox. He is one of the few lawyers in our firm who has read every page of the US FATCA regulations (both the Chapter 3 and 4 portions), as well as the OECD CRS Standards, Commentary and Implementation Handbook, and stands ready to explain all the new international transparency and automatic exchange of information regimes without putting the audience to sleep. A tax lawyer who speaks plain English (well American), Richard would be happy to discuss arcane points of international compensation planning and the use of bilateral tax treaties to minimize US tax on investment income, but he would rather delve into which type of bitters to add to his next recipe for raspberry jam.

Richard is our resident tax guru. No, really, he has had the e-mail address taxguru@aol.com since 1992. But please use his Withers e-mail for work related communication since the spam filter on the other address is quite savage these days and we wouldn’t want urgent information to be overlooked.

Secretary Karolyn DeGrand

Track record

Admissions

Publications

Memberships

Talks

Structuring UK operations for a hedge fund management company.

Structuring joint venture for US and UK investors in carbon trading operations.

US tax compliance and trust planning for wealthy Asian family.

State of New Jersey, 1986

State of New York, 1987

State of Florida, 1993

State of Illinois, 1996

State of Connecticut, 2002

_’_Hedge Funds Still Can’t Figure Out A Way to Avoid 457A Tax Bill’, Bloomberg News - June 2016, quoted

Hedge Fund Earnings Wash Ashore’, Connecticut Journal Inquirer - June 2016, quoted

_’_A Comparison: FATCA and Common Reporting Standard’, Journal of International Taxation - March 2016, co-author

American Bar Association

‘Tax issues facing family investment partnerships’, New York State Society of CPAs, New York - June 2016

‘Tax Compliance for International Clients - FATCA and CRS’, AICPA National Conference, Las Vegas - January 2016

‘Structuring Partnership Equity Compensation’, Federal Tax Institute of New England - October 2015

Education


Languages


  • English

Dates


Joined

2001

Recognition


New Haven

157 Church Street,

CT 06510-2100

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New York

430 Park Avenue,

10th Floor,

NY 10022-3505

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