30 November 2021 - Article
Developed and implemented international trust and entity structures through which international clients invested into the United States, avoided estate tax exposure and maintained confidentiality.
Structured and drafted domestic and foreign trusts to facilitate gifts to U.S. beneficiaries, or to achieve various asset protection, tax efficiency and confidentiality goals.
Advised single family office on restructuring of offshore trusts and migration of underlying assets to newly structured trusts that better facilitated reporting and operational efficiencies and substantially reduced ongoing costs.
Counseled U.S. clients residing abroad on U.S. income and transfer tax and information reporting issues, and worked with local counsel to implement coordinated planning.
Assisted domestic clients with preparation of estate plans to minimize gift and estate tax exposure, and to shift investment opportunities from one generation to another.
Provided pre-immigration planning to foreign individuals planning to establish domicile in the U.S.
Work with clients to obtain additional passports and to renounce their United States citizenship, along with guiding such clients through the associated tax and information reporting implications.
Coordinate with local counsel on matters, including, but not limited to, foreign estate plans for U.S. clients relocating abroad, investment structuring for U.S. and non-U.S. persons, planning with offshore trusts, and related matters.
Advise clients on structuring, formation and operation of private trust company (PTC) in various U.S. and non-U.S. jurisdictions, as well as single family office and affiliated entities.
Consult on estate administration matters and represent fiduciaries of U.S. and non-U.S. estates and trusts with respect to U.S. tax reporting and optimization, fiduciary obligations, administration and related matters.
Counseled clients on U.S. and international issues, often in conjunction with local advisors, relating to every continent (except Antarctica), including, but not limited to the following jurisdictions: Mexico, Argentina, Colombia, Chile, Peru, Antigua, Dominican Republic, Canada, China, Hong Kong, Vietnam, Japan, Singapore, South Africa, Australia, Switzerland, France, Italy, Spain, Belgium, Germany, UK, Russia and CIS countries.
Previously served as a judicial intern to Senior Judge James S. Moody, Jr. (U.S. District Court, Middle District of Florida); Judge Maurice M. Paul (U.S. District Court, Northern District of Florida); and Catherine P. McEwen (U.S. Bankruptcy Court, Middle District of Florida).
District of Columbia
US Tax Court
US District Court, Northern District of Texas
‘Withers Breaks Into Texas as It Continues US Expansion,’ Texas Lawyer - September 16, 2021, quoted
‘International law firm sets up UHNWI tax and estate planning practice in Texas,’ International Investment - September 10, 2021, quoted
‘Wake Up Call: Firms Try to Ease Anxiety of Office Returns,’ Bloomberg Law - September 9, 2021, featured
‘Withers Enters Texas Market With Houston Office,’ Law360 - September 9, 2021, quoted
‘U.K. Firm Withers Looks to Serve Tax Needs of Well-Heeled Texans,’ Bloomberg Tax - September 9, 2021, quoted
‘Withers enhances private client and tax capabilities with launch of Texas practice,’ Withers Insight - September 8, 2021, featured
‘A Brave New World: U.S. Implements Company UBO Reporting Regime,’ Winstead News Alerts – January 8, 2021, author
‘Foreign Inbound Investment In A Coronavirus World: Beware The US Estate Tax,’ Texas Tax Lawyer Journal (Spring 2020, Vol. 47, No. 3) – June 17, 2020, author
‘Foreign Inbound Investment in a Coronavirus World: Beware the U.S. Estate Tax,’ Winstead News Alerts – May 4, 2020, author
‘U.S. Tax Reform and Its Impact on Swiss Companies,’ Expert Focus (The Swiss Trustee/Der Schweizer Treuhander) – March 1, 2018, co-author
‘Resident or Not: Recent Developments in Determining Individual Tax Residency Under U.S. International Tax Treaties,’ Tax Notes International – November 1, 2017, author
‘Look Before You Leap: Considerations and Consequences of U.S. Expatriation,’ Trusts and Trustees (September 2017, Vol. 23, No. 7) - May 10, 2017, co-author
‘Self-Employed or Not at All: Passive Investor Income Is Not Always Subject to SECA Tax,’ The Estate Planner (Trusts & Estates) – May 1, 2017, co-author
‘Artificial Intelligence and the Wealth Management Space,’ Wealth Management – March 21, 2017, co-author
‘Impact on Business Valuations of Lapsed Rights and Restrictions on Liquidation of an Interest: Is this the End of Valuation Discounting as We Know It?’ Wealth Management – August 30, 2016, co-author
‘The Only Thing Certain Is Uncertainty: The Future of Estate Planning Without the Federal Estate Tax,’ Real Property, Trust and Estate Law Journal (Vol. 51, No. 1) – March 1, 2016, co-author
Society of Trust and Estate Practitioners (STEP), Trust and Estate Practitioner (TEP)
State Bar of Texas, Tax Law Section’s International Tax Committee, Vice Chair
State Bar of Texas, Real Estate, Probate & Trust Law Section, Member
American Bar Association, Taxation and Real Property, Trust and Estate Law Sections, Member
International Bar Association, Member
State Bar of Florida, Real Property, Probate Law and Tax Law Sections, Member
‘Nuts and Bolts of U.S. Estate and Gift Tax Treaties,’ State Bar of Texas Tax Section’s International Tax Symposium, Houston, Texas – November 22, 2019, presenter
‘FIRPTA Traps, Pitfalls and Planning Opportunities,’ State Bar of Texas Tax Section’s International Tax Symposium, Houston, Texas – November 21, 2019, presenter
‘Individual International Income Taxation and Compliance,’ American Bar Association Real Property, Trust and Estate Law Section’s Fundamentals on International Tax Series – July 23, 2019, presenter
‘The Anatomy of the Form 706-NA,’ American Bar Association Tax Section, Washington, D.C. – May 10, 2019, presenter
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29 November 2021 - Article
Shannon Smith and Hallie Aronson co-author "How to Survive an IRS Crypto Tax Audit" article for Forkast News
29 November 2021 - Podcast
Withers talks: Leveling the playing field with Michael Rueda | Episode 4 - Philanthropy and activism for athletes, entertainers, and other notable individuals
25 November 2021 - Article