The US tax rules governing the taxation of equity awards for globally mobile employees are complex and in some cases, uncertain. Among other things, employers must consider the type of award, grant and vesting dates, and sourcing rules to ensure proper reporting and withholding for non-US employees that have worked in the United States. The
Ryan J. Coyle focuses his practice on international tax matters, 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 has extensive experience advising on US anti-deferral legislation (i.e., Subpart F and GILTI) applicable to non-US entities that become controlled foreign corporations as a result of migration to the United States. In addition, he advises on planning related to tax treaty interpretation, expatriation, qualified small business stock (QSBS), the Foreign Investment in Real Property Tax Act (FIRPTA), and international enforcement initiatives such as the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS). Ryan also advises non-US residents on US gift and estate tax rules affecting non-US residents with US income and assets, as well as US residents with non-US income and assets.
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. He advises on the formation of private trust companies to serve as trustees of family trusts and assists trust companies with compliance requirements.
Having been based in London and Hong Kong at various points in his career, Ryan has unique insight into the needs of global clients and speaks extensively on topics related to international taxation.