Global Mobility of Ultra-High-Net-Worth Individuals
This title, featuring contributions by leading private client advisers from 16 key jurisdictions worldwide, provides readers with expert guidance on the tax and legal aspects of inbound and outbound transfer of residence of ultra-high-net-worth individuals.
However these individuals must consider a wide range of factors when deciding whether to relocate internationally, and so advisers need to take a holistic approach.
This title, featuring contributions by leading private client advisers from 16 key jurisdictions worldwide, provides readers with expert guidance on the tax and legal aspects of inbound and outbound transfer of residence of ultra-high-net-worth individuals. Chapters cover the relevant law in their respective jurisdictions relating to:
It also considers the application of tax treaties to beneficial tax regimes, and the relocation of works of art, as well as other key topics.
This book will be an invaluable tool for lawyers, tax advisers, bankers and all professionals who assist ultra-high-net-worth individuals.
Table of Contents
|Table of Contents||3|
|Part I: Jurisdictions||7|
|Part II. General topics||269|
|The succession law ramifications of relocation||269|
|Relocation – planning to avoid the pitfalls on divorce||285|
|Relocation and works of art||299|
|Fiscal nomads: the impact of relocation on CRS and DAC6||313|
|The application of tax treaties to individuals subject to beneficial tax regimes||325|
|About the authors||337|
|About Globe Law and Business||347|
This publication could not have come to market at a more propitious time. As the world begins to open up again, the trend towards international mobility will resume – and especially among ultra-high-net-worth individuals and, not infrequently, their dependents.
The first half of the volume consists of in-depth tours d’horizon of fifteen different countries, reviewed by expert advisors drawn from leading law firms, accountants and family offices. As one might expect, they guide the reader through the complexities of the commercial and personal tax regimes of countries as varied as China, Monaco and the United States. Throughout, the topics are illustrated with examples that bring to life what might otherwise be a series of purely technical discourses.
A bonus is the second half. In this a select number of authors discuss a number of contemporary issues, such as the “fiscal nomad” and the relocation of works of art. Much of this is revelatory: what might appear relatively straightforward to the lay person, is shown to be complex and multi-layered, with unintended consequences for the unwary. Of particular interest are the comparisons between civil and common law jurisdictions, and the implications for immigration, changes in family circumstances such as divorce, and tax planning for succession purposes.
This book should be a standard work of reference on the shelf of every advisor to the mobile high-net-worth community.
This topical and comprehensive publication definitely deserves space in the library of any self-respecting advisor dealing with wealthy families and their affairs. Nicola has brought together a top drawer panel of contributors covering all of the key jurisdictions and a number of the most relevant associated subject areas including; succession law, the impact of tax treaties and an up-to-date position on the oft referenced but misunderstood subject of “fiscal nomads”. The next few years will undoubtedly see wealth owners focus attention on the issue of tax residency as the consequences of the pandemic evolve in terms of funding its cost and their own increased focus on quality of life where they can exercise a choice between competing jurisdictions.
Partner, Speed and Stracey Lawyers
Daniel Appleby (BBus, LLB, LLM) is a partner of Speed and Stracey Lawyers in Sydney. He has advised private groups and family offices (including some of Australia’s most successful) – primarily on taxation, Australian and international closely held structures, and succession – for over 20 years. He is an academician of the International Academy of Estate and Trust Lawyers (TIAETL) and a member of the Taxation Committee of the Law Council of Australia; is regularly in liaison with the Australian Taxation Office on behalf of clients; and is a contributor to STEP and other Australian taxation publications.
Maria Inês Assis
Professional partner, Abreu Advogados
Maria Inês Assis has a degree in law from the Nova University Lisbon, Faculty of Law (2007). She is currently a professional partner in the tax team at Abreu Advogados. After concluding an LLM in international taxation at the International Tax Center Leiden, she specialised in international tax matters. Maria has considerable experience advising private clients and family groups (directly and through the private banking and wealth management sector) on wealth management and protection and the preservation of private wealth, ensuring the generational transfer of family assets in a tax-efficient manner. Maria has been recognised as a rising star since 2019 as a subjectmatter expert on tax matters relating to financial instruments and transactions, portfolio vehicles, asset-holding structures, life insurance, trusts and so on.
Partner, Arkwood SCP
Stéphanie Auféril is a founding partner of Arkwood SCP. She advises families on all their wealth management tax matters. Her expertise is recognised in the following areas: French-US strategies – she assists numerous US persons with relocation to France or investments in France, as well as French individuals relocating to or investing in the United States; wealth planning via trusts for foreign (notably US) families with French connections; and the provision of assistance to families and family businesses in their structuring, development and estate planning, in a domestic and international context. In 2017 Stéphanie won the STEP Geoffrey Shindler Award for Outstanding Contribution to the Profession for her success in challenging the French Registry of Trusts before the French Constitutional Court in 2016. In 2018 she won Citywealth’s Entrepreneurial Woman of the Year Award. Stéphanie is a member of STEP, the Institut des Avocats Conseils Fiscaux Wealth Management Commission and TIAETL.
Nuno Cunha Barnabé
Partner, Abreu Advogados
Nuno Cunha Barnabé is a graduate of the law faculty of the University of Lisbon (1996), where he lectured in tax, public finance and economics law (1996–1999). He was a senior tax consultant at the former Arthur Andersen Portugal (1996–2000). He is a founding judge of the Portuguese Tax Arbitration Court (2011). Before joining Abreu (2019), he headed the tax practice at PLMJ and coordinated the firm’s private client division (2000–2019). Nuno is currently a senior partner at Abreu, where he co-heads the tax practice, with responsibility for private clients. He has over 20 years’ experience in tax law and specialises in wealth taxation, advising high-networth individuals (HNWIs), individuals, family offices, private banking and asset manager businesses in Portugal and Portuguese-speaking countries. Nuno is a member of STEP (Central London branch, 2017) and TIAETL (2017). He is recognised as an expert in his field by numerous legal directories.
Dean C Berry
Partner, Cadwalader, Wickersham & Taft LLP
Dean C Berry is head of the private client department at Cadwalader, Wickersham & Taft LLP in New York. He specialises in complex international trust and estate planning for US and non-US HNWIs and family groups. He works with clients and other advisers to develop effective and tax-efficient strategies for the preservation, governance and transfer of private wealth, using vehicles such as trusts, private companies, partnerships and foundations. He also represents professional fiduciaries, philanthropic donors and non-profit charitable organisations. Dean is a frequent lecturer at seminars and conferences around the world, and is a member of TIAETL.
Senior associate, Hughes Fowler Carruthers
Archie Best works in all areas of family law, and in particular on complicated financial cases, divorce, nuptial agreements, matters relating to children and international law. The Legal 500 UK 2021 praises him as a “talented associate”. Archie works mainly with Mark Harper, who describes him as “a class act”, “critical in winning cases” and “brilliant at preparing for trial”. He was a key contributor to the third edition of International Trust and Divorce Litigation (Jordan Publishing, 2019).
Pupil barrister, Gray’s Inn Tax Chambers
Benjamin Blades commenced a 12-month pupillage at Gray’s Inn Tax Chambers in October 2020 after working as a research assistant for Laurent Sykes QC for three years. He has been involved in work on issues involving both private clients and corporations, often with an international dimension.
Prior to his work at Gray’s Inn Tax Chambers, Ben read law and Spanish law at Christ Church, Oxford.
Associate, Arkwood SCP
Claire Brisset joined Arkwood SCP as an associate in 2016. Within Arkwood, Claire mostly assists non-residents – with a focus on Middle Eastern clients – on real estate investments in France. She also deals with the settlement of international successions and assists artists and sportspeople in a cross-border context.
Claire graduated from the Master II Gestion du patrimoine privé et professionnel of Panthéon- Assas University and from DJCE Caen University. She was admitted to the Paris Bar in 2016.
Florentino Carreño is a partner at Cuatrecasas in Madrid. He is an expert in asset structuring between countries and generations, the application of double tax treaties and the international automatic exchange of information for tax purposes. He also focuses on structuring private equity, hedge funds and insurance. Florentino developed his career at the firm’s London office from 2006 to 2009. An elected academician of TIAETL, he is currently its president. He is also an elected international fellow of the American College of Trust and Estate Counsel (ACTEC). This experience has enabled him to acquire in-depth knowledge of common law wealth structures.
He lectures on the master’s in EU law at Universidad Carlos III de Madrid (UC3M) and is a member of the programme’s academic board. He also lectures on the master’s in tax at UC3M and Universidad de Navarra in Madrid. He has written several books and articles for the general and specialised press in Spain and abroad.
Senior director, Christie’s
Ruth Cornett is the senior director in the heritage and taxation advisory service at Christie’s. She initially trained as an art historian and was a curator in the V&A Museum prior to changing career. Ruth studied law and qualified as a chartered tax adviser and member of STEP while working in the City. At Christie’s, Ruth advises on all areas of practice involving heritage and the taxation of chattels: private treaty sales, offers in lieu of inheritance tax and claims for conditional exemption. Ruth sits as an observer on the Taxation and Political Committee of Historic Houses and has lectured for STEP, Historic Houses and Christie’s Education. As part of her role at Christie’s, Ruth advises and guides applicants through the export licence process. Ruth contributed to the recent review of the export licence system undertaken by the Department of Culture, Media and Sport and is a recognised expert in this field.
Dominique De Bie
Dominique De Bie received her master’s degree in law from KU Leuven in 2006. She completed her education with a complementary master’s in notarial law in 2007 and a postgraduate degree in estate planning at the Vrije Universiteit Brussel in 2010. She has been a member of the Antwerp Bar since 2007. In 2015, she joined the Tiberghien estate team. She concentrates on estate planning, tax advice and procedures concerning family estate law and private international law. Dominique worked as a part-time assistant at the Rector Dillemans Family Estate Law Institute for four years (2012–2016). She is fluent in Dutch, French and English.
Xavier de Sarrau
Managing partner, Gordon S Blair Law Offices
A doctor in tax law (Paris Sorbonne) and a HEC Paris graduate, Xavier de Sarrau is the managing partner of Gordon S Blair Law Offices, a legal practice which was founded more than 80 years ago in the principality of Monaco to cater for the needs of global families and ‘citizens of the world’. He took over that firm from Ernst & Young in 2007 and has since developed it greatly. This firm now employs over 40 people, with offices in Monaco and Geneva.
Prior to taking over Gordon S Blair, Xavier spent most of his career at Arthur Andersen, where he was managing partner for the Europe, Middle East, India and Africa region. In 2002 he founded his own legal practice in Geneva, specialising in advising global families and private groups on structuring their affairs.
Consultant, Russell-Cooke LLP
Richard Frimston is a consultant with Russell- Cooke LLP where he was a partner from 1982 and head of private client until 2018. He has particular expertise in dealing with multi-jurisdictional estates, especially with France. He is a member of the Law Society’s EU Committee and STEP’s Council and of the European Law Institute, the European Association of Private International Law and TIAETL. Richard has co-edited The International Protection of Adults for Oxford University Press and commentaries on the EU Succession Regulation and the EU Regulations on the Matrimonial and Partnership Property Regimes.
Gerd D Goyvaerts
Gerd D Goyvaerts is a partner at Tiberghien. His tax practice covers professional and private estate taxation of Belgian entrepreneurs and HNWIs; international corporate and private tax planning; death duties and estate planning; and tax-inspired migration from and to Belgium. He also has a special interest in tax issues relevant to Anglo- Saxon trusts, foundations and settlements; and in voluntary disclosure proceedings, anti-money laundering legislation and regulations. In addition, Gerd has developed a keen interest and devoted practice in look-through taxation, nicknamed ‘Cayman tax’ in Belgium. Gerd regularly speaks and writes on tax issues. He is a senior officer of the Private Client Committee of the International Bar Association (IBA) Anti-Money Laundering Action Group; president of the Belgian Association of Tax Lawyers (BATL); an international fellow of ACTEC; and a member of TIAETL. He is former president and vice president of the Tax Commission of the Association Internationale des Jeunes Avocats (AIJA).
Partner, Hughes Fowler Carruthers
Mark Harper is a divorce specialist at Hughes Fowler Carruthers in London, particularly international cases involving trusts and prenuptial agreements. He was president of the European Chapter, International Academy of Family Lawyers from 2014–2016. He is the coauthor of the recently published third edition of International Trust and Divorce Litigation (Jordan Publishing, 2019). Mark was ranked in the Top 10 divorce lawyers in Spear’s Family Law Index 2013–2021. The Legal 500 UK 2021 praises Mark as a “family law super star”. The Legal 500 UK 2020 called him “a brilliant lawyer who does the biggest cases”.
Associate, Schellenberg Wittmer
Ksenia Iliyash is an associate in the private wealth group at Schellenberg Wittmer SA in Geneva, Switzerland. She graduated from the University of Geneva and was admitted to the Geneva Bar in 2019. She advises private clients, family offices and trustees on all aspects of wealth planning, including domestic and international taxation, marital property agreements, inheritance, trusts, foundations and art law. Her practice further includes administrative litigation, especially relating to the Organisation for Economic Cooperation and Development’s (OECD) Common Reporting Standard for Automatic Exchange of Financial Account Information in Tax Matters (CRS).
Associate, Zhong Lun Law Firm
Sakura Ji is an associate in the tax and wealth planning practice of Zhong Lun Law Firm and specialises in providing international legal and tax services to individuals and companies. Her work covers various tax aspects of cross-border transactions. In addition, she advises private clients on wealth planning and individual tax compliance and planning.
Sakura also advises clients on regulatory and legal aspects of cross-border investments and wealth planning, such as those relating to foreign investment law, corporate law and foreign exchange.
Legal director, Charles Russell Speechlys LLP
David Lingham is a legal director in the private client team at Charles Russell Speechlys LLP. He advises individuals, trustees, private banks and others on the establishment, reorganisation and UK tax treatment of legal structures for the protection of, and succession to, private wealth, particularly where there is an international element; and he works closely with advisers in other jurisdictions. He has particular expertise on the UK tax treatment of pension arrangements and also advises on the design and tax-efficient funding of philanthropic arrangements.
Caroline Maes is an associate at Tiberghien. Her tax practice covers professional and private estate taxation of Belgian entrepreneurs and HNWIs, international tax planning, death duties and estate planning. She is a frequent speaker at seminars organised by the Antwerp Tax Academy, Tiberghien Congress and Assuralia. She is also an editorial secretary of Tax Clicking magazine (Tijdschrift Beleggingsfiscaliteit/Revue Fiscalité des Placements) and a member of the Antwerp Bar. Recently, Caroline completed SUPRALAT training at the Bar, which will allow her to deepen her focus on criminal tax law.
Partner, RMW Law LLP; consultant, Withers LLP
Samantha Morgan works with a number of international family offices, advising on all aspects of UK tax, reporting and fiduciary issues, and coordinating foreign tax and other advice for the family office and family members.
Samantha is a member of the STEP UK Technical Committee and the STEP Public Policy Committee. She has given STEP-sponsored webinars and seminars on the CRS, the EU Directive on Cross-Border Tax Arrangements, mandatory disclosure rules and the corporate offence of failure to prevent the criminal facilitation of tax evasion pursuant to Part 3 of the Criminal Finances Act 2017. She was also part of the STEP team working directly with the OECD in discussing the implementation of the CRS and on draft guidance, including attending meetings with OECD and Her Majesty’s Revenue and Customs and preparing draft guidance on behalf of STEP.
Partner, Zhong Lun Law Firm LLP
Clifford Ng is a partner of Zhong Lun’s Hong Kong office and head of the firm’s private client practice. He is a leader in the private client industry in Hong Kong.
Having worked with some of Asia’s leading businesses and families for over 30 years, Clifford provides strategic advice on cross-border transactions and investments, tax, regulatory, estate planning, asset preservation and governance. Clifford is noted for providing innovative solutions to complex issues, having worked extensively in multi-jurisdiction transactions and handled a broad range of issues, including asset protection investment strategies, trust and estate litigation, securities regulatory issues, family estate battles and creditor claims. Clifford has been ranked in Private Client/Wealth Management in Hong Kong by Chambers since 2012. He has been recognised as a leading lawyer in the Citywealth Leaders List, Who’s Who Legal and as a Global Private Client Elite by Legal Week. He was also ranked in Private Client by the Legal 500 Asia Pacific Guide 2021. He was recently recognised for his lifetime achievement in the Greater China WealthBriefingAsia Awards.
Partner, Zhong Lun Law Firm
Peter Ni is a partner and an executive committee member of Zhong Lun Law Firm. Before joining Zhong Lun, he led White & Case’s Greater China tax practice. Prior to that, he led the international tax practice of Ernst & Young China. He is the vice chairman of the Tax Committee of the PRC Bar Association and an officer of the Tax Committee of the IBA.
Peter has more than 23 years of experience in providing international tax and legal services to companies and individuals with cross-border needs, including nine years in the United States. Peter has been ranked as a leading tax lawyer in China by Chambers, International Tax Review, Tax Directors Handbook and Legal 500 Asia-Pacific, and as a leading private client lawyer in China by Chambers and Who’s Who Legal.
Partner, Charles Russell Speechlys LLP
James Riby has been a partner in the family law team at Charles Russell Speechlys LLP since 2012 and has been ranked as a leading lawyer in Legal 500 and Citywealth’s Leaders List. He advises and represents clients on all areas of private family law. He is also a trained mediator and collaborative lawyer. He has particular experience in Anglo-Italian cases, where he is recognised as a leading expert due to his high profile in Italy, fluency in Italian and time spent working in the country, and also deals with a large number of Anglo-Swiss matters. He has particular expertise dealing with complex cross-border jurisdiction disputes and in the past few years has been a member of Resolution’s advisory working party on Brexit. He is also known for his expertise on property disputes between non-married couples, pensions and the complex relationship between insolvency and divorce claims, and co-authors the LexisPSL guide on the same.
Founding partner, RMW Law LLP; consultant, Withers LLP
John Riches works with prominent international family offices on a cross-border basis and deals with structuring for UK residents and resident non-domiciled families. He creates structures for active entrepreneurs to hold business interests and frequently advises on issues relating to the interaction of family and business governance. He is frequently listed in many publications as a leading private client adviser to international families. He has a deep interest in tax and regulatory policy, and enters into regular dialogue with national and supranational bodies to represent the profession.
John has received numerous accolades over many years, including Trusted Adviser of the Year at the 2011 STEP Private Client Awards and the Spears Tax and Trust Lawyer of the Year Award 2017. He is regularly ranked in the top tier of private client lawyers globally in international directories and is widely regarded by his peers.
Associate, RMW Law LLP
Eleanor Riches-Lenaghan qualified as a private client solicitor in October 2020 and is an associate in boutique private client law firm RMW Law LLP. Prior to this, Eleanor undertook her training contract at Winckworth Sherwood LLP, gaining knowledge and experience in data protection and regulation, commercial real estate and licensing, property litigation and private client. Eleanor has a particular interest in cross-border policy, writing dissertations on beneficial ownership registers and deemed domicile for her master of laws. Since qualification, Eleanor has undertaken significant research into international tax policy issues. She has also co-authored a chapter, “The origins of beneficial ownership registers in the European Union”, in Beneficial Ownership Registers, published by Globe Law and Business in 2021. Eleanor is in the process of obtaining her STEP Diploma in Trusts and Estates.
Elie S Roth
Partner, Davies Ward Phillips & Vineberg LLP
Elie S Roth is a partner in the taxation law practice group in Toronto. His practice concentrates on all aspects of domestic and international tax planning, corporate taxation and private client matters. He has also represented taxpayers in tax audits and tax litigation proceedings at all levels of Canadian courts, including the Supreme Court of Canada.
Elie has taught international tax law as an adjunct professor and taxation of real estate transactions at Osgoode Hall Law School. He speaks frequently at legal conferences on taxation issues in Canada, the United States and Europe. Elie is co-author of the textbook Canadian Taxation of Trusts (Canadian Tax Foundation, 2016), among other books and publications. He is a member of the International Fiscal Association Canada council; a former governor of the Canadian Tax Foundation; a council member and member of the Taxes Committee of TIAETL; and an international fellow of ACTEC.
Partner, Maisto e Associati
Nicola Saccardo is a partner at Maisto e Associati and heads the London office. He graduated from Bocconi University in Milan and holds an LLM in international taxation from the University of Leiden (the Netherlands). He is admitted to the Italian Bar (he is also qualified as Italian chartered accountant). He specialises in taxation of HNWIs, trusts and estates, as well as estate planning in general.
He is the chair of the Tax Committee of TIAETL; a member of the International Estate Planning Committee of ACTEC; the chair of the International Client Global Special Interest Group Steering Committee of STEP; a member of the EU Public Policy Committee of STEP; and a member of the Responsible Stewardship of Wealth Thought Leadership Sub-group of STEP.
He is ranked as leading expert in several legal directories, has authored many publications on Italian tax matters and is a frequent speaker at conferences.
Partner, Cyril Amarchand Mangaldas
Kunal Savani is a partner in the direct tax and private client practice of Cyril Amarchand Mangaldas. In addition to being a lawyer, he is a qualified chartered accountant.
Kunal specialises in tax laws relating to family settlements/constitutions, trusts, wills, gifts and succession planning, and has over 16 years of post-qualification experience. He also advises on other aspects of direct tax, such as corporate tax, international tax and inbound and outbound M&A transactions. His experience also includes conceptualising and evaluating tax-efficient alternatives and plans for acquisitions/ divestments, mergers/demergers and business/ corporate reorganisations, with a view to minimising transaction costs and/or tax exposure based on the commercial objectives of the stakeholders involved.
William S Schaaf
Special counsel, Cadwalader, Wickersham & Taft LLP
William Schaaf is a special counsel in Cadwalader’s private client department. He advises US and non-US individuals, families and fiduciaries on a broad range of matters, including US and international trust and estate planning; US income, estate, gift and generation-skipping transfer tax planning; business succession planning; and charitable giving.
William is a member of the American Bar Association (Section on Real Property, Trust and Estate Law) and the New York State Bar Association (Trusts and Estates Law Section). He graduated with a BA from Haverford College, and earned his JD from the University of Pennsylvania Law School and his LLM in taxation from New York University School of Law. He is admitted to practise in the State of New York.
Partner, Cyril Amarchand Mangaldas
Rishabh Shroff is a partner in Cyril Amarchand Mangaldas, based in its Mumbai office. He is the co-head of the private client practice and specialises in cross-border estate and succession planning, family constitutions and settlements, trusts, wills and overall succession planning. He provides succession, taxation, estate and wealth planning advice to wealthy individuals and their families, who are often promoters of large family businesses.
Since 2017, Rishabh has been consistently ranked as one of the world’s top specialist private client/family business lawyers by the UK’s Private Client Global Elite. He is the founding chairman of the Federation of Indian Chambers of Commerce and Industry Young Leaders Forum – Maharashtra Chapter, and a board member of the Confederation of Indian Industry’s Family Business Network. Rishabh is also a published author and writer. His journey as a fourthgenerational family member was featured in The Inheritors: Stories of Entrepreneurship and Success by Sonu Bhasin (Penguin Books, November 2017).
Laurent Sykes QC
Tax barrister, Gray’s Inn Tax Chambers
Laurent Sykes QC is a tax barrister practising from Gray’s Inn Tax Chambers. He has a wide-ranging practice which encompasses many areas of the tax code, particularly business and employment taxrelated matters and domicile and other issues affecting private clients. He also advises on taxrelated pensions matters and on tax-related commercial disputes. In the past, Laurent qualified as a chartered accountant, which provides useful background knowledge in dealing with tax questions with an accounting aspect. Litigation (usually for the taxpayer and where necessary) is an important part of his work and has taken him to the Tax Tribunal, the High Court and the Court of Appeal. He speaks Italian and French fluently, and dabbles in some other languages.
Partner, Schellenberg Wittmer
Bernard Vischer is a partner in Schellenberg Wittmer’s Geneva office, where he heads the private wealth group. He graduated from Geneva University and holds an LLM from the University of Pennsylvania, He was admitted to the Geneva Bar since 1980 and is a trust and estate practitioner. Bernard advises banks, trust companies, family offices and private clients on private banking matters, trusts, estate planning and philanthropy. He especially advises entrepreneurs and families on governance, dispute prevention and succession in privately held/ controlled businesses. He is a professional coach certified by IDC. He also holds several board positions with Swiss banks and family enterprises, and has extensive practical experience in corporate and transactional matters, with a focus on the banking, shipping and aviation industries.
Christian von Oertzen
Partner, Flick Gocke Schaumburg
Christian von Oertzen is a partner at Flick Gocke Schaumburg and head of the private client department. He is based in the Frankfurt office. He has more than 25 years of experience in advising national and international clients on estate planning, probate, income tax and capital gains tax matters, as well as on immigrating to or expatriating from Germany.
Christian lectures regularly on these legal and tax issues and has published several manuals and articles on estate and capital gains tax planning, conflict of laws questions and exit taxation. He is a member of several prestigious professional institutions, including TIAETL, STEP and ACTEC.
Associate, Davies Ward Phillips & Vineberg LLP
Ryan Wolfe is an associate in the taxation law practice group in Toronto. Ryan is developing a comprehensive tax practice focused on domestic and cross-border planning, mergers and acquisitions and tax audits and disputes. Ryan received his BA (with distinction) from the Ivey Business School at the University of Western Ontario and his JD (with distinction) from the
University of Western Ontario.