Ryan is an attorney in the Tax and Employee Benefits department. Ryan has extensive experience in international tax planning for both businesses and individuals. He also provides domestic tax advice to partnerships, corporations, S corporations, and their respective owners on various business transactions, including formations, mergers, acquisitions, internal restructurings, and divestitures.
In his international tax practice, Ryan provides U.S. tax advice to both U.S. businesses with foreign operations and foreign businesses with U.S. operations. These businesses face issues such as whether they should be structured as flow through or corporate entities for U.S. tax purposes and whether their activities in a particular country amount to a permanent establishment under a relevant income tax treaty. Other issues applying to these clients can be the application of U.S. anti-deferral regimes including Subpart F, global intangible low-taxed income (“GILTI”), and passive foreign investment companies (“PFICs”).
For individuals, Ryan provides pre-immigration planning advice to foreign persons prior to establishing U.S. tax residency. He also advises U.S. residents on the tax implications of relinquishing U.S. citizenship or terminating lawful permanent residency (“green card”) status.
Ryan also provides tailored U.S. tax advice to foreigners planning on investing in U.S. real estate by taking into consideration the source country, U.S. tax return filing obligations, U.S. estate and gift tax considerations, planned exit strategy, and other relevant factors.
Ryan has been quoted on international tax issues in The Wall Street Journal, The Washington Post, Tax Notes Today, and other media outlets. He earned his J.D., as well as a certificate in tax studies, from the University of Connecticut School of Law
Representative Cases and Achievements
- Designed and implemented strategy that reduces the effective tax rate of new Code §965 transition tax by 10 percentage points for certain taxpayers.
- Created plan for an inbound reorganization of advertising company to eliminate “sandwich structure” and achieve one level of U.S. tax on worldwide operations.
- Revised a European private equity fund’s proposed exit from media company in order to save a U.S. partner nearly $500,000 of tax.
- Provided ownership structuring advice to foreign individuals and companies looking to invest in U.S. real estate.
- Dean’s Scholar Recipient, University of Connecticut School of Law, 2007-2010
- Andrew Mitchell LLC – International Tax Attorneys
- Internal Revenue Service, Office of Chief Counsel (Strategic Litigation), Legal Extern
- University of Connecticut School of Law, Tax Clinic, Legal Intern
Civic and Charitable Involvement
Contributions & Published Works
- The Wall Street Journal (quoted)
- Washington Post (quoted)
- Tax Note Today (quoted)