Samantha Rinaldi
Tax Attorney
- Role
- International Tax Attorney at Christopher J. Byrne Pllc
- Location
- New York, NY, US
- LinkedIn followers
- 500 followers
About Samantha Rinaldi
I concentrate my practice on international taxation of high net worth individuals and…
Experience
International Tax Attorney
Apr 2020 — Present · New York, NY, US
Advise ultra-high net worth clients with cross border issues including pre-immigration planning, expats, expatriation, controlled foreign corporations (\"CFCs\"), passive foreign investment companies (“PFICs”), investment in U.S. real estate, trusts, gifts and inheritance from non-U.S. persons etc. Research and analyze inbound and outbound international tax, tax treaties and prepare client memorandums. Draft and review promissory notes, operating agreements, corporate resolutions, etc. Negotiate and communicate with the Internal Revenue Service, New York State Department of Taxation and Finance and various state revenue agencies. Review tax return filings including but not limited to Forms 1040, 1040NR, 706-NA, 926, 8621, 3520, 3520-A, 8938, 5471, 114, 1042, 1042-S, 8865. Prepare Forms 8288, 8288-A, W-7, W- 8BEN-E, W-8BEN, W-8IMY, W-9.
Education
St. Thomas University College of Law
Juris Doctor (J.D.)
2009 — 2012
University of Miami School of Law
Master of Law (LL.M.), Taxation
2011 — 2012
University of Miami Herbert Business School
Bachelor of Business Administration, Finance, Marketing, Business Management
2005 — 2009
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