Controlled Foreign Corporations And the OBBBA

Carl Merino represents multinational families and companies on a wide range of personal and business tax matters, with a focus on cross-border income and estate tax planning.

Carl works extensively in the international tax arena. He advises non-U.S. clients on structuring inbound investments to minimize federal and state income and estate tax exposure. He advises U.S. clients on tax aspects of foreign investments, including application of the passive foreign investment company (“PFIC”) and controlled foreign corporation (“CFC”) rules, utilization of foreign tax credits, entity classification issues and reporting requirements for foreign entities and trusts, tax treaties and other issues. His work in this area also encompasses pre-immigration and expatriation planning, tax issues of foreign trusts with U.S. beneficiaries (including coordination of subchapter J with the CFC and PFIC rules), and corporate structuring for foreign companies setting up U.S. operations.

Carl is recognized as a leading complex international tax planning attorney by Chambers HNW* (Chambers & Partners). In the 2024 edition of Chambers HNW, a source stated that “Carl is a technical powerhouse with respect to the U.S. side of cross-border tax matters. His technical ability is second to none”.

Carl is on the International Practice Committee of the Editorial Advisory Board of Trusts & Estates Magazine.