The Long Arc of AttributionThe Long Arc of Attribution

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.