Samuel Rosen focuses his legal practice on complex tax matters, with an emphasis on federal tax law, international tax structuring, and estate and gift tax planning for high-net-worth individuals and multinational clients. Known for his technical precision and strategic tax analysis, Samuel counsels clients on a broad range of issues, including entity structuring, inbound and outbound investment tax planning, FATCA and FBAR compliance, and advanced estate planning techniques involving GRATs, IDGTs, and charitable giving structures.
Samuel earned his Juris Doctor from the University of California, Hastings College of the Law, where he graduated with honors and served on the Hastings Law Journal. He went on to earn an LL.M. in Taxation from New York University School of Law, widely regarded as the nation’s top tax program. He is recognized as a Certified Tax Law Specialist by the State Bar of California Board of Legal Specialization and is admitted to practice before the United States Tax Court.
His practice includes advising U.S. citizens and residents on the tax consequences of cross-border transactions, expatriation under IRC §877A, and pre-immigration tax planning. He also assists clients with IRS audits, offshore disclosure programs, and private foundation formation and compliance.
Representative Matters:
– International Tax Planning: Structured the foreign ownership of a U.S. real estate portfolio through blocker entities and treaty-based planning to minimize exposure to FIRPTA and effectively manage withholding obligations.
– High-Net-Worth Estate Structuring: Created a comprehensive estate plan for a client with more than $150 million in assets, incorporating a series of grantor and non-grantor trusts to reduce estate tax exposure and protect generational wealth.
– IRS Controversy: Represented a tech entrepreneur in a complex audit involving equity compensation and international holdings; secured significant reductions in proposed penalties and a favorable closing agreement.
– Expatriation and Exit Tax Compliance: Guided multiple clients through the legal and tax implications of expatriation, including preparation of Form 8854, analysis of mark-to-market gains, and planning for covered expatriate classification.
– Nonprofit and Foundation Work: Formed and obtained tax-exempt status for a family-run charitable foundation, advising on governance, self-dealing rules, and compliance with IRC §4940–4945.
Samuel is a member of the American Bar Association’s Section of Taxation and the International Fiscal Association, and he frequently collaborates with financial advisors, CPAs, and fiduciaries in implementing tax strategies aligned with his clients’ long-term goals.