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Seth J. Mersky is an international tax attorney with significant experience in all areas of U.S. international tax law. His practice is exclusively focused on assisting high-net worth individuals and multinational businesses with U.S. inbound and outbound tax planning and international trust and estate planning.
In the inbound area, Seth assists non-U.S. individuals and foreign businesses with structuring their U.S. investments in a tax-efficient manner. In doing so, Seth works hand-in-hand with clients' non-U.S. legal and tax advisors to ensure that investments are structured in a manner that is tax-efficient from a worldwide perspective and accounts for non-income tax impacts such as U.S. and foreign wealth transfer taxes.
In the outbound area, Seth assists U.S. individuals and domestic businesses with structuring their offshore operations in a tax-efficient manner considering global tax impacts and opportunities to minimize or defer the payment of U.S. federal income taxes. In that respect, he has extensive experience advising U.S. clients who own interests in non-U.S. business entities that constitute controlled foreign corporations (CFCs) or passive foreign investment companies (PFICs).
A significant portion of Seth's practice is focused on assisting high-net worth and ultra-high-net worth individuals and families with their global trust and estate planning needs. He is experienced in all matters related to the design, formation and operation of U.S. and foreign trust structures, as well as the U.S. federal tax impacts of establishing or being a beneficiary of domestic and foreign trusts. Working closely with clients' foreign legal and tax advisors, Seth assists in guiding international families of significant wealth through the process of creating an international estate plan that ensures worldwide wealth is preserved and transferred to successive generations in a smooth, private manner, and with the lowest possible impact from global gift, estate, generation-skipping and inheritance taxes.
Certificate in International Tax, cum laude