Avi Guttman

Avi is a cross-border Canada/US tax, trust and estate planning lawyer. Licensed in Ontario, New York and New Jersey, Avi provides tax and estate planning advice to high net-worth individuals and families with a Canadian and US footprint, including US citizens living in Canada, Canadians owning or purchasing US assets, US residents owning Canadian assets, beneficiaries of cross-border trusts and estates. Avi understands the legal and tax complexities involved in the cross-border context and helps craft innovative solutions that minimize tax in both countries, preserve family wealth, and meet his clients’ ultimate estate planning objectives.

Avi’s areas of expertise include IRS compliance for US citizens and residents owning Canadian assets. Avi counsels US clients on the consequences of owning shares in private Canadian companies, including the anti-deferral Controlled Foreign Corporation (“CFC”) and Passive Foreign Investment Company (“PFIC”) rules. Avi also counsels US beneficiaries of Canadian trusts on their US obligations as beneficiaries of foreign trusts, including reporting requirements and the “throwback tax” rules. Avi advises clients on alternate structures to minimize US tax consequences, often revising family structures created without consideration of the US consequences and possible double taxation in Canada and the US. Avi has counseled clients ranging from modest family trusts to multi-million dollar corporate structures.

Avi also has expertise counseling Canadian clients purchasing US real estate for personal use or investment purposes. Avi assists clients in devising the most tax-efficient structure for their investment, including through the use of trusts, partnerships, corporations, or hybrid structures. Avi has assisted with investments ranging from personal use condominiums to multi-million dollar commercial properties.