Baker & McKenzie
Learn about us Locally »
English (Change Language)
Baker & McKenzie
Learn about us Locally
Combining the knowledge of local laws and cultures with a global reach is just one of the ways Baker & McKenzie separates itself from other firms. Our genuinely global perspective allows us to operate without boundaries around the world, in every jurisdiction that is important to your business.

Select a region or country to learn about on-the-ground resources immersed in the local culture or Learn about us Globally to view our talent and services worldwide.

When content is available in multiple languages, please select your preference on the right.

Baker & McKenzie Holds Briefing on Potential US Tax Trap

Firm News
24 January 2013
Explaining US Citizenship by Derivation

Zurich, Switzerland, 24 January 2013 - Within the framework of the regular business briefings organized by Baker & McKenzie Zurich, Thomas Salmon and Daniel W. Hudson welcomed attendees to a briefing on the topic of U.S. citizenship by derivation, which poses as a U.S. tax trap for the unwary.

Mr. Hudson first explained some of the driving forces behind the heightened sensitivity to the determination of whether a client is a U.S. citizen, which included a brief overview and update on the Foreign Account Tax Compliance Act (FATCA). The final regulations under FATCA where released by the United States Internal Revenue Service last week, which are intended to provide further guidance for the implementation and operation of FATCA.

Mr. Salmon then explained how an individual can be a U.S. citizen by derivation, wherein a person with no other ties to the United States as from a U.S. citizen parent, is deemed a U.S. citizen and therefore a U.S. taxpayer. Mr. Salmon further discussed requirements to be considered a U.S. citizen by derivation. Mr. Salmon finished by highlighting the potential U.S. federal income, estate and gift tax consequences for a U.S. citizen.

The briefing finished with Mr. Hudson explaining that expatriation is one way for a U.S. citizen by derivation to relinquish their U.S. citizenship. Such explanation included the limitations to expatriation. Finally, Mr. Hudson and Mr. Salmon discussed some of the facts to keep an eye out in order to determine whether a client might be deemed a U.S. citizen by derivation.   

For any questions about this press release, please contact:

Marnin Michaels ( +41 44 384 1208)
Thomas Salmon ( +41 44 384 1372)
Daniel W. Hudson ( +41 44 384 1290)
For further information, please contact:
Associate Director, Communications, EMEA
+44-20 7919 1731
Search Globally

Search Globally
Alphabetical by Last Name
Every day our more than 4,000 lawyers, economists, tax advisors and other professionals share insights and best practices across borders and practices. We speak more than 75 languages and represent more than 55 nationalities, and the close relationships among our people fosters the trust needed to develop and deliver world-class solutions to multinational clients.

We share an uncompromising commitment to excellence, which explains why more of our lawyers are included as leading lawyers in the Chambers Global Guide to the World’s Best Lawyers than any other Global 20 law firm.

To find a Baker & McKenzie lawyer or other professional, enter a search parameter to the left.
Passionately global
We are passionately global — it's in our DNA.

We started with a vision of going global and were in eight countries before our 10th anniversary. Today we have 77 offices in 47 countries -- including the emerging markets so important to the growth of your business.
*Associated Firms
**In cooperation with Trench, Rossi and Watanabe Advogados
Other Geographic Initiatives

We service clients throughout the world and in some countries where we do not have offices, working with carefully selected local firms to leverage our global knowledge and capabilities.

 India Africa Central America 
  Central Europe   
We offer world-class career opportunities around the globe, while our entrepreneurial culture makes Baker & McKenzie a unique place to develop professionally.

Explore us Locally by selecting a region, country or office below, or select Submit to view our site Globally.