
Overview
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.
* No aspect of these advertisements has been approved by the highest court of any state. See Awards Methodology.
Education and Credentials
Education
- New York University School of Law, LL.M. in Taxation
- University of California, Berkeley School of Law, J.D.
- American Jewish University, B.A., summa cum laude
Admissions
- State of New York
Affiliations
- Society of Trust and Estate Practitioners (STEP)
- Steering Committee, Cambridge International Wealth Advisors Forum 2.0
- New York State Bar Association, International Section, Committee on International Estate and Trust Law
Recognition and Community
No aspect of this advertisement has been approved by the highest court of any state. Prior results do not guarantee a similar outcome. See Awards Methodology.
Recognitions
Chosen for inclusion in The Best Lawyers in America (Woodward/White, Inc.), Trusts and Estates, 2023-2025
Chosen for inclusion in Chambers HNW Guide (Chambers & Partners) as a leading lawyer for wealthy individuals and families in New York, 2021-2024
News & Insights
Thought Leadership
- The Long Arc of Attribution , October 21, 2024
- U.S. Tax Planning for Non-U.S. Persons, Assets and Trusts - An Introductory Outline , September 18, 2024
- Are You Required to Participate in Bureau of Economic Analysis' Benchmark Survey? , May 1, 2023
- Pre-Residency Planning for Your Client's Trust , October 22, 2021
- UPDATE: Increased Telecommuting Raises State Tax Issues , January 11, 2021
News
- Chambers High Net Worth Recognizes 18 Day Pitney Attorneys for Private Wealth Law, July 18, 2024
- Day Pitney Secures Solutions for International Americans Award at the Family Wealth Report Awards 2024, May 6, 2024
- Chambers High Net Worth Recognizes 20 Day Pitney Attorneys for Private Wealth Law, July 20, 2023
- Chambers High Net Worth Recognizes 20 Day Pitney Attorneys for Private Wealth Law, July 22, 2022
- Day Pitney Represents Geneva-Based Crescendo Capital in Forming Cayman Islands Real Estate Co-Investment Fund, November 29, 2021
In The Media
Publications
- U.S. Federal Estate, Gifts and GST Taxation of Nonresident Aliens, The Chamber's International Tax Journal, December 3, 2020
- Beware the Life Insurance Tax Trap, Private Asset Management, May 1, 2016
- Charitable Constraints, Private Funds Management, August 13, 2015
- What Donors Need to Know About Appreciated Property, Private Asset Management, June 1, 2014
Speaking Engagements
- Neither Here Nor There: Foreign Trusts and the Multinational Family, January 10, 2025
- "Advising Clients on Incorporating Sustainability, Social Impact and Philanthropic Goals into Family Business and Wealth Succession Structures," Cambridge Forum for International Wealth Advisors, May 16, 2024
- Using Foreign Partnerships to Hold U.S. Situs Assets, Interplay with 663(b) and FAI Planning, 19th Annual International Estate Planning Institute, March 14, 2024
- "Mobility Issues," Forum for International Wealth Advisors – 2nd Generation, May 12, 2023
- "17th International Estate Planning Institute," International Section, Trusts & Estates Law Section, New York State Bar Association and STEP-NY, April 1, 2022
- "Little-Known Wrinkles in Foreign Trusts – Skills to Avoid Pitfalls in Practice," 16th Annual International Estate Planning Institute: Part 2, March 18, 2021
- "Reporting by U.S. Person of Foreign Income, Assets and Transactions," STEP Colorado Formation and STEP Chicago, February 24, 2021
- Planning Tips and Pitfalls for International Estate Planners, December 8, 2020
- Cambridge International Wealth Advisors Forum 2.0, May 17, 2019
- Non-Residents Acquiring Real Estate: Compare & Contrast Between the U.S. & UK, May 2, 2019
- 15th Annual International Estate Planning Institute, March 14-15, 2019
- Estate Planning Across Borders: A Guide for the Perplexed, January 16, 2019
- Acquiring U.S. or UK Real Estate, November 13, 2018
- The Life Cycle of a Foreign Trust - Tax Planning for Foreign Trusts with US Beneficiaries, September 21, 2018
- U.S. Tax Reform Discussion II: Inbound Real Estate Investing, August 22, 2018
- Investment in U.S. Real Estate by Nonresident Aliens (NRAs), May 21, 2018
- 14th Annual International Estate Planning Institute, March 22-23, 2018
- Purchase of U.S. Real Estate by Foreign Nationals, November 7, 2017
- Recent Developments in International Estate Planning: The U.S. Begins to Embrace Transparency, October 18, 2017
- Dina Kapur Sanna and Carl A. Merino Speak at International Wealth Advisors Forum, June 15, 2017
- Living in a Glass World: A Global Transparency Outline for Wealth Advisors, May 25, 2017