Attribution After the TCJAAttribution After the TCJA

Carl Merino is of counsel in the New York office of Day Pitney LLP. He represents high net worth individuals and families, multinational companies and exempt organizations on a wide range of personal and business tax matters, including cross-border tax planning, compensation arrangements, corporate and partnership tax issues, charitable giving and income taxation of trusts and estates.

Carl works extensively in the international tax arena. He advises non-U.S. clients on structuring inbound investments to minimize income and estate tax exposure and U.S. clients on tax aspects of foreign investments, including anti-deferral rules, entity classification issues and reporting requirements for foreign entities and trusts. His work in this area also encompasses pre-immigration tax planning, employment tax issues for expatriates working abroad and foreign workers in the U.S. and corporate structuring for foreign companies setting up U.S. operations.

Carl regularly advises clients on the use of domestic and foreign grantor trusts, S corporations and other flow-through structures. He collaborates with trusts and estates colleagues on estate planning transactions and other wealth migration issues and advises exempt organizations on nonprofit and employment-related tax matters.

Carl frequently publishes articles on cross-border tax planning, charitable giving and other tax issues.

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Dina Kapur Sanna, partner in the Individual Clients Department, practices in the area of U.S. federal tax planning for high net worth individuals with property interests and/or heirs in more than one country.

Dina has considerable experience in the development of wealth management structures for residents and nonresidents of the United States. Such structures accommodate multijurisdictional tax and legal considerations in order to maximize tax efficiency from a global perspective, particularly where future generations are, or may become, residents or domiciliaries of the United States. She has had significant exposure to U.S. federal income and transfer tax issues affecting U.S. residents with non-U.S. assets and income and nonresidents with U.S. assets and income, including income and transfer tax treaty analysis and interpretation; rules applicable to income taxation of complex non-U.S. trusts and their beneficiaries; the antideferral regimes relevant to direct and indirect U.S. shareholders of certain non-U.S. corporations; and preimmigration and expatriation tax planning.

Dina is a frequent speaker at international tax and estate planning seminars around the world, including New York, Miami, Los Angeles, London, Switzerland, and Bermuda. She also has written or co-written several articles on international estate planning topics that appeared in periodicals such as The New York Law Journal, Trusts & Estates magazine, the STEP USA Journal; and Estate Planning magazine.

Dina received her B.A. in Economics, magna cum laude, from Lehigh University in 1993, where she was a member of Omicron Delta Epsilon, the International Economic Honorary Society. She received her J.D., with Honors, from the George Washington University National Law Center in 1996, where she also graduated Order of the Coif. Dina also holds a Master of Law (LL.M.) degree in taxation from New York University School of Law, which she received in January 2000.

Dina was recognized as a leading wealth management attorney by Chambers USA Legal Directory and has been consistently included in Best Lawyers in America since 2007. She is a fellow of the American College of Trusts and Estate Counsel (ACTEC).

Seth J. Mersky is an international tax attorney with Day Pitney LLP. His practice is exclusively focused on assisting high-net-worth individuals and multinational businesses with U.S. international tax planning and international estate planning matters. Seth regularly advises U.S. and foreign clients on all aspects of U.S. inbound tax planning, U.S. outbound tax planning, and international trust and estate matters.