He is familiar with the taxation of partnerships, LLC s, 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 [email protected] 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.
‘Tax Treatment of Carried Interest: Planning Opportunities for Tax, Private Equity and Real Estate Professionals’, Strafford Publications - July 2018, webinar
‘PPLI /PPVA: Its Time Has Come’, M Group National Conference, Laguna Niguel, CA - February 27, 2018
‘The US Tax Cuts and Jobs Act of 2017 - What wealth management professionals outside the US need to know’, Withers seminar, Geneva and Zurich - January 2018
‘Planning Considerations for Foreign Grantor Trusts and Update on the IRS Voluntary Disclosure Program’, Morgan Stanley International Wealth Conference - December 19, 2017
‘Intergenerational Split Dollar Insurance Planning’, Private Placement Life Insurance and Deferred Variable Annuity Forum - June 13, 2017
‘US Tax Aspects of Inbound Investing and Immigration’, China Merchants Bank Conference - April 12, 2017
‘Form 3520 Foreign Trust Reporting for Tax Counsel: Navigating Filing Requirements and Penalty Abatements for Delinquencies’, Strafford National Webinar - April 6, 2017
‘Structuring Foreign Investment in U.S. Real Estate: Entity Selection and Transaction Structures’, Strafford Webinar - February 16, 2017
‘Is Your Client Tax-Ready to be a Lawful Permanent US Resident?’, Knowledge Group National Webinar - October 25, 2016
‘Tax issues facing family investment partnerships’, New York State Society of CPA s, 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
‘Tax Aspects of International Wealth Management’, Morgan Stanley, New York - October 2015
‘US Tax Issues Facing Israeli Residents’, UBS Private Client Seminar, Tel Aviv, Israel - May 2015
_’Tax Issues Facing International Life Insurance and Private Placement Policies’, II_R PPLI Conference, London - May 2015
‘Charitable Gift Planning Using Charitable Lead Trusts’, New Jersey Estate Planning Council, New Jersey - January 2015
‘Tax and Reporting Requirements on US Executives and Owners of Foreign Corporations’, ANEFAC /Monterrey Tax Club, New York - September 2014
‘Tax Savings Opportunities in the PPLI / PPVA Market’, Tippett Morehead presentation, San Diego - July 2014
‘US Real Estate Investment: Tax and Legal Issues for Non-US Investors’, Friedman LLP, New York - June 2014
‘Top Ten Reasons for Foreign Wealth to Continue to Invest in the US’, Morgan Stanley International Wealth Management, New York - June 2014
‘FATCA and Foreign Trusts’, Bermuda Association of Licensed Trustees, Hamilton, Bermuda - May 2014
‘Use of Life Insurance in Cross-Border Tax Planning’, CRUM /CPAM, New York - April 2014
‘Reducing Tax on Active Business Alternative Investments’, Landmark Venture Forum, Greenwich, Connecticut - March 2014
‘Advanced Concepts in Deferred Compensation’, New Haven Chamber of Commerce, New Haven, Connecticut - October 2013
‘Tax on Foreign Shares Owned by US Persons’, CT CPA Society - August 2013
‘Reporting Foreign Financial Accounts Held by US Persons’, CT CPA Society, Hartford, Connecticut - July 2013
‘International Insurance Planning’, Transnational Taxation Network, New York - May 2013
‘FATCA Checklist for Buy-Side Firms - Where Should You be Now?’, presented at Financial Technology Forum FATCA Briefing, New York - March 2013
‘FATCA - Where Should Buy-Side Firms Be Now?’, Financial Technologies Forum, New York - February 2013
‘Intergovernmental Agreement’, FATCA Implementation Summit, New York - December 2012
‘Tax Consequences of Hedge Fund Structures’, Hedge Fund Tax 101, New York - June 2010
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.
‘Reshaping the IRS, ’ Accounting Today - May 01, 2018, quoted
‘Tax Cuts and Jobs Act: Impact on Chinese Clients’ Wealth and Business Interest Planning,’ This article will appear in a forthcoming issue of Journal of International Taxation (Thomson Reuters/Checkpoint.)
‘House Tax Bill is Littered with Loopholes for Wall Street’s Wealthiest,’ Bloomberg News - November 21, 2017, quoted
‘The House Tax Plan is Conveniently Full of Drafting Glitches that Benefit the Rich,’ Vanity Fair - November 21, 2017, quoted
‘Tax Reform Bill Delays Estate Tax Repeal, Retains Basis Step-Up,’ Tax Notes - November 03, 2017, quoted
‘House and Senate Budget Measures Advance Tax Reform,’ Accounting Today - October 06, 2017, quoted
_’_ 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
‘Introduction to FATCA and Its Impact on Chinese Investment Funds’, Shanghai Stock Exchange Securities Law Review, December 2015 - co-autho
American Bar Association
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