Speaker details

Biography

Ryan J. Coyle focuses his practice on US aspects of international tax, 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 applicable to non-US entities that become controlled foreign corporations, oftentimes with regard to 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). 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.