Jacopo Crivellaro

Biography

Jacopo Crivellaro is a partner in Baker McKenzie's Tax and Global Wealth Management practice groups in Zurich. He joined the Firm in 2013 after pursuing graduate law studies in the US and the UK. Jacopo has published extensively on US, international tax and estate planning matters in academic and practitioner journals, and has recently co-authored a book on the Foreign Account Tax Compliance Act (FATCA), the Common Reporting Standard (CRS) and trust planning in Italy. He is a regular speaker at wealth management conferences and has recently co-presented a four-part series of webinars on private client developments with the Baker McKenzie Milan office.

Practice Focus

Jacopo focuses his practice on international estate and trust planning with a US, UK, Swiss or Italian connection. He has advised individuals on pre-immigration and mobility planning, asset protection, cross-generational transfer and multinational tax and estate planning advice, including the treatment and recognition of trusts in a cross-border context. Jacopo has recently advised the executors of several complex international estates on legal and tax issues associated with the collection and distribution of estate assets to beneficiaries situated in civil and common law jurisdictions.

Representative Legal Matters

Advised the executor of a USD 100 million+ estate, involving assets situated in more than 15 jurisdictions, on the estate distribution and liquidation process.
Advised the US beneficiaries of a USD 15 million foreign non-grantor trust on the restructuring of the trust following the death of the grantor.

Professional Honors

Young Practitioner of the Year, Society of Trust and Estate Practitioners (STEP) Private Client Awards, 2019
Worldwide Excellence Awards, STEP, 2017

Professional Associations and Memberships

Member, STEP, Secretary of the Lugano branch

Admissions

Geneva Art. 28 BGFA~Switzerland (2020)
England & Wales~United Kingdom (2019)
New York~United States (2013)
U.S. Tax Court~United States (2013)

Education

New York University (Executive LLM in Tax) (2018)
Oxford University (St. Catherine's College) (BCL) (2013)
King's College London (LLB English & American Law) (2012)
Columbia Law School, United States (JD) (2012)

Languages

English
Italian

Previous Offices

Geneva

Publications

Author, La pianificazione patrimoniale al di la' della morte: la terapia crionica, Trusts & Wealth Management Journal, January 2023
Author, Pianificazione patrimoniale nell’era digitale, Trusts & Wealth Management Journal, December 2022
Co-author, High Profile: Social Media's Impact on the Private Client World, STEP Journal, November 2022
Co-author, Trust Registers in Europe: The Changing Landscape of the 5th Money Laundering Directive, Trusts & Wealth Management Journal, January 2020
Co-author, D.C. Circuit Court of Appeals Pins IRS in Grecian Magnesite Mining Case, but a Hollow Victory for Taxpayers Prospectively, Baker McKenzie Tax News and Developments, July 2019
Co-author, Updates to donor disclosure rules in the US and UK, Private Wealth Newsletter, December 2018

Co-author, Taxes through the lens of Cristiano Ronaldo, Wealth Management, October 2018
Co-author, Considerazioni fiscali in relazione alla Filantropia Internazionale, Trusts & Wealth Management Journal, July 2018
Co-author, Tax Law Shake-Ups In Swiss Wealth Management, Law360, May 2018
Co-author, Forme di Pianificazione Fiscale Patrimoniale, Dike Giuridica, May 2018
Co-author, Italy’s Preferential Tax Regime for New Residents, The Global Citizenship Review, March 2018
Co-author, US Tax Reform and its impact on Swiss Companies, Expert Focus, March 2018
Co-author, A maze with little guidance, STEP Journal, February 2018
Co-author, Grecian Magnesite Mining and potential legislative developments under the Tax Cuts and Jobs Act of 2017, Baker McKenzie Private Wealth Newsletter, December 2017
Co-author, Resident or Not: Determining Individual Tax Residency Under U.S. Tax Treaties, Tax Notes International, November 2017
Co-author, A Grecian Tragedy for the IRS: Tax Court Rejects Rev. Rul. 91-32, Journal of Taxation, November 2017
Co-author, Fare Well When Moving: Changing Tax Home and Expatriating, Estate Planning Journal, November 2017
Co-author, Grecian Magnesite Mining: Tax Court chimes in on Rev. Rul. 91-32, and it’s music to taxpayers’ ears, Baker McKenzie Tax News and Developments, October 2017
Co-author, Il Trust come strumento di pianificazione successoria nel Medio Oriente, Trusts & Wealth Management Journal, July/December 2017
Co-author, Not so straightforward: Using trusts for estate planning and wealth management in the Middle East, Baker McKenzie Private Wealth Newsletter, June 2017
Co-author, Estate Planning that complies with Sharia Law principles, Wealth Management, May 2017
Co-author, CRS implementation: five things to think about before 2017, Diritto Bancario, December 2016
Co-author, II regime di tassazione in uscita per persone fisiche: una panoramica degli sviluppi recenti, Trusts & Wealth Management Journal, December 2016
Co-author, The Shifting Minefield of Exit Taxes, The Global Residence and Citizenship Review, October 2016
Co-author, Wealth Management and Estate Planning in the Gulf Countries, Estate Planning Journal, October 2016
Co-author, Owning and disposing of works of art: A wealth management perspective from Switzerland - Part 1, Baker McKenzie Private Banking Newsletter, September 2016
Author, Global mobility and exit taxes, Schroders Wealth Management, July 2016
Co-author, A primer on wealth management and estate planning in the Gulf countries, Baker McKenzie Private Banking Newsletter, June 2016
Co-author, Turbulence Ahead, STEP Journal, May 2016
Co-author, EU Succession Regulation can affect Non-Member State Nationals, Estate Planning Journal, April 2016
Co-author, A practical guide to the new European Succession Regulation, Wealth Gram, Groupement Suisse des Conseils en Gestion Indépendants, April 2016
Co-author, Considerazioni Sulla Voluntary Disclosure Statunitense, Diritto e Pratica Tributaria Internazionale, March 2016
Co-author, Global Mobility and Exit Taxes: An Overview of Recent Trends, Baker McKenzie Private Banking Newsletter, March 2016
Co-author, II regime di tassazione in uscita per persone fisiche: una panoramica degli sviluppi recenti, Trusts & Wealth Management Journal, March 2016
Co-author, The EU Succession Regulation and its impact for non-Member States and non-Member State nationals, Trust & Trustees, March 2016
Co-author, Cross-Border Succession Planning in Europe: A Practical Guide to the New European Succession Regulation – The essential answers for Testators and Beneficiaries, Baker McKenzie Publication, February 2016
Co-author, A Rough Guide to the EU Succession Regulation, STEP Journal, January 2016
Co-author, FATCA: ricadute per intermediari finanziari, Diritto Bancario, January 2016
Co-author, Ricadute Del Regolamento Ue N. 650/2012 – Sulle Successioni Transfrontaliere Che Coinvolgono Paesi Terzi, Trusts & Wealth Management Journal, December 2015
Co-author, Damned if you do…, STEP Journal, June 2015
Co-author, How encouraging Clients to participate in Voluntary Disclosure may have made the situation for Banks worse, International Tax Review, April 2015
Co-author, Programmi Di Voluntary Disclosure: Le Reazioni Degli Istituti Finanziari, Trusts & Wealth Management Journal, March 2015
Co-author, IRS Issues New Guidance on Streamlined Filing Compliance Procedures, Baker McKenzie Client Alert, October 2014
Co-author, Modifiche al Programma di Regolarizzazione Fiscale Statunitense: la Voluntary Disclosure (OVDP/Programma Streamlined), Diritto Bancario, October 2014
Co-author, IRS Modifies OVDP and Streamlined Filing Compliance Procedure, Journal of International Taxation, September 2014
Author, Conseguenze della mancata presa in considerazione di elementi rilevanti nell'amministrazione di un trust da parte di un trustee: II principio Hastings-Bass dopo le sentenze Futter v Futter e Pitt v Holt, Trusts & Wealth Management Journal, December 2013
Author, Una Prospettiva Sull’Industria Del Wealth Management: Nei Paesi Del Golfo, Trusts & Wealth Management Journal, September 2013

Events

Co-panelist, Cyber security, data protection and trustee liability, STEP Alpine Conference, Interlaken, 4 May 2023
Co-presenter, Famílias globais: mudança de residência para Europa e atualidades no planejamento sucessório europeu, Trench Rossi Watanabe Webinar, LiveTrench, 6 April 2023
Co-presenter, Recent Tax & Private Client Developments in Europe, Baker McKenzie Wealth Management Roundtable, Miami, 2 February 2023
Presenter, Strumenti e istituti di pianificazione successoria nell'ordinamento svizzero, Centro Studi Villa Negroni, 25 January 2023
Co-presenter, Reporting Regimes for Beneficial Owners in the EU, UK and Switzerland, Baker McKenzie Wealth Management Briefing, Zurich, 12 January 2023
Co-presenter, Workshop: un controverso caso di successione internazionale, Centro Studi Villa Negroni, 10 January 2023
Guest Lecturer, Master on Cross-Border Financial Services, Transfer Pricing (e la sua importanza per un Family Office), , Centro Studi Villa Negroni, 1 December 2022
Co-presenter, Privacy vs Transparency: Beneficial Ownership Developments, Transatlantic Wealth & Estate Planning Conference, London, 30 November 2022
Guest Lecturer, Master on Cross-Border Financial Services, Percorso di transizione da Family Office a Private Investment Firm, Centro Studi Villa Negroni, 25 November 2022
Co-presenter, Complex Tax and Reporting Issues for International Clients and Family Trusts, Global Wealth Management and Family Office Conference, 10 November 2022
Co-presenter, Global Wealth Management Trends and Developments, Global Wealth Management and Family Office Conference, 10 November 2022
Co-presenter, The future of the trusts and obligations of Swiss professionals, Finix Events, 10 November 2022
Co-presenter, Taxation of Trusts in Italy - Recent changes and what they mean for you, Wealth Management EMEA Briefings, 8 November 2022
Co-presenter, Updates from Near and Far: the Gulf, North Africa, UK, the EU and Singapore, Baker McKenzie Switzerland Wealth Management Strategy Meeting, Thun, 10 June 2022
Co-presenter, Benefits, Pitfalls and Other Considerations in Using Trusts in International Planning, 14th Annual STEP International Tax and Estate Planning Forum, Laguna Beach, 6 May 2022
Co-presenter, Competing Property Rights and Regimes, 14th Annual STEP International Tax and Estate Planning Forum, Laguna Beach, 6 May 2022
Co-presenter, Special Immigration Tax Regimes, 14th Annual STEP International Tax and Estate Planning Forum, Laguna Beach, 5 May 2022
Co-presenter, Cross-Border Planning Non-Tax Drivers, Baker McKenzie NATPG Global Wealth Management Training, Miami, 2 May 2022
Co-presenter, Corporate mobility: issues to consider when exiting jurisdictions and investments, Baker McKenzie Webinar, 30 November 2021
Co-presenter, Workshop: un controverso caso di successione internazionale, Centro Studi Villa Negroni, 19 October 2021
Co-presenter, Opportunities and Traps: Wealth Planning in Africa & the Middle East, Baker McKenzie Webinar, 7 October 2021
Co-presenter, Cross-Border Estate Planning: the US, the UK and Switzerland, Baker McKenzie Switzerland Wealth Management Strategy Meeting, Saas-Fee, 3 September 2021
Presenter, Cross-Border Successions in the Digital Era, STEP Lugano Webinar, 28 April 2021
Co-presenter, Succession Planning Strategies for Cross-Border Families, Baker McKenzie Webinar, 23 March 2021
Co-presenter, Polizze estere e mobilità internazionale, Unione Giovani Dottori Commercialisti ed Esperti Contabili di Milano Webinar, 10 December 2020
Co-presenter, Practical Experiences of Italy's Preferential Tax Regimes for New Residents, Baker McKenzie Webinar, 3 December 2020
Co-presenter, Family Office Private Equity Investments, Baker McKenzie Webinar, 29 October 2020
Co-presenter, So I Married a US Person, Baker McKenzie Webinar, 27 October 2020
Co-presenter, Planning with Trusts and Corporate Vehicles, Baker McKenzie Webinar, 20 October 2020
Co-presenter, DAC 6 reporting in real life situations, Academy & Finance SA, Zurich, 29 September 2020
Co-presenter, Sportsmen: Planning and mobility, Baker McKenzie Webinar, 29 September 2020
Co-presenter, DAC 6: the EU mandatory disclosure regime, Baker McKenzie / Trench Rossi Watanabe Internal Training, Saas-Fee, 10 September 2020
Co-presenter, Help, my kids want to relocate, what do I do?, Baker McKenzie Switzerland Wealth Management Strategy Meeting, Saas-Fee, 4 September 2020
Co-presenter, New Global Wealth Structures in an Era of Populism, Inequality and the COVID-19 Pandemic, Baker McKenzie Switzerland Wealth Management Strategy Meeting, Saas-Fee, 3 September 2020
Co-presenter, Planning for Swiss Clients with US and/or UK connections, Baker McKenzie Switzerland Wealth Management Strategy Meeting, Saas-Fee, 3 September 2020
Co-presenter, Commodity Trading Hubs - Tax and Transfer Pricing Issues, Baker McKenzie Webinar, 14 July 2020
Co-presenter, Current Developments Overview - Switzerland, Italy and the UK, STEP Chicago Webinar, 14 July 2020
Co-presenter, CRS Compliance and Audits, DAC6, and Beneficial Ownership Registers, Baker McKenzie Webinar, 25 June 2020
Co-presenter, Pianificazione patrimoniale per atleti, Baker McKenzie Webinar, 17 June 2020
Co-presenter, COVID-19 tax/legal considerations for clients with connection to Poland/EU, Russia, Ukraine, UK & US, Baker McKenzie Webinar, 4 June 2020
Co-presenter, La pianificazione successoria Italia-Stati Uniti, Baker McKenzie Webinar, 28 May 2020
Co-presenter, Patrimoni artistici di famiglia: gestione, protezione e successione, Baker McKenzie Webinar, 14 May 2020
Co-presenter, Family office, Governance familiare, passaggio generazionale e filantropia, Baker McKenzie Webinar, 7 May 2020
Presenter, Ripercussioni giuridiche e fiscali della Brexit in Svizzera, STEP Lugano Webinar, 6 April 2020
Co-presenter, Family Offices as a Tool for Successful Family Business Successions, Baker McKenzie Business Briefing, Geneva, 4 February 2020
Co-presenter, DAC6 and Practitioner Reporting, Baker McKenzie Internal Training, San Diego, 30 January 2020
Co-presenter, Family Offices as a Tool for Successful Family Business Successions, Baker McKenzie Business Briefing, Zurich, 21 January 2020
Presenter, Trust in Switzerland: The New Law Is Coming, Finix Events, Zurich, 27 November 2019
Co-presenter, Ambiti di utilizzo del trust, casi concreti, esperienze italiane e internazionali, Milan, 16 October 2019
Co-presenter, On a tightrope: Reconciling fiduciary duties with ethical investments, Zurich, 2 October 2019
Co-presenter, Baker McKenzie 20th Annual Tax & Trust Training Program, New York, September 2019
Co-presenter, Reconciling Fiduciary Duties with Ethical Investments, Baker McKenzie Business Briefing, Geneva, 10 September 2019
Co-presenter, Trusts Demystified, NextGen Summit at Valueworks, Zurich, 28 June 2019
Co-presenter, Family Governance in the 21st Century, Baker McKenzie Switzerland Wealth Management Strategy Meeting, Saas-Fee, 27 June 2019
Co-presenter, La Dolce Vita: An Update on Recent Developments in Italy, Baker McKenzie Business Briefing, Zurich, 20 June 2019
Co-presenter, La Dolce Vita: An Update on Recent Developments in Italy, Baker McKenzie Business Briefing, Geneva, 13 June 2019
Co-presenter, CRS and change of tax residence, Academy & Finance SA, Geneva, 7 June 2019
Co-presenter, Key regulatory, legal and tax developments in Russia and the EU/Switzerland, Lugano, 25 March 2019
Co-presenter, Danger Ahead! Cones on the road, tolls and potholes: Residence and Citizenship -what are the wider tax, succession and property implications?, Baker McKenzie Roundtable, Geneva, 5 December 2018
Co-presenter, Strumenti di Pianificazione Patrimoniale alla luce delle normative europee ed extraeuropee, Trusts & Wealth Management Journal Conference, Milan, 4 December 2018
Guest Lecturer, FATCA & CRS, Master of Advanced Studies in International Taxation (MASIT) 2018, University of Lausanne, November 2018
Co-presenter, Baker McKenzie 19th Annual Tax & Trust Training Program, Miami and New York, October 2018
Co-presenter, Charitable Giving: Tax and Legal Issues in the US, UK, Switzerland and Italy, Baker McKenzie Business Briefing, Geneva, 9 October 2018
Co-presenter, Trust Law Changes, Baker McKenzie Switzerland Wealth Management Strategy Meeting, Saas-Fee, 6 July 2018
Co-presenter, Baker McKenzie 2018 Asia Pacific Wealth Management Conference, Hong Kong and Singapore, April 2018
Co-presenter, Global Families: Challenges in Times of Uncertainty, Baker McKenzie Roundtable, Zurich, 11 April 2018
Co-presenter, International Trust Planning: Key considerations when advising clients with links to China, Hong Kong, Indonesia or Singapore, Baker McKenzie Business Briefing, Zurich, 5 April 2018
Co-presenter, Wealth Management from a Swiss Perspective: Automatic Exchange of Information, Baker McKenzie Roundtable, Milan, 15 March 2018
Co-presenter, US Tax Reform Workshop: Planning for Opportunities and Pitfalls, Baker McKenzie Roundtable, Geneva, 2 March 2018
Co-presenter, Corporate And Pass Through Reform: What Does This Mean For Our Clients, Baker McKenzie Internal Training, Dallas, 24 January 2018
Co-presenter, Transparent or Opaque: Treatment of Multi-Jurisdictional Trusts in Switzerland, Germany, Italy, France and the UK, Baker McKenzie Business Briefing, Zurich, 5 October 2017
Co-presenter, Changes in favorable tax regimes for non-residents, Baker McKenzie Business Briefing, Zurich, 23 March 2017
Presenter, Amnesties: Italian Voluntary Disclosure, Baker McKenzie Internal Training, Toronto, 9 February 2017
Co-presenter, EU Private Law Questions, Baker McKenzie Internal Training, Zurich, 17 January 2017
Co-presenter, Recent developments in Italy, Baker McKenzie Business Briefing, Zurich, 30 November 2016
Co-presenter, Automatic Exchange of Information: reporting obligations for Companies & Directors and Trusts & Trustees, Academy & Finance SA, Lugano, 28 November 2016
Co-presenter, Philanthropy for High Net Worth Individuals: Structure choices and jurisdictions, Baker McKenzie Business Briefing, Zurich, 17 November 2016
Co-presenter, Automatic Exchange of Information: Intended and Unintended Consequences, SDA Bocconi-School of Management, Milan, 25 October 2016
Co-presenter, Global Mobility, Exit Taxes & Expatriation, Baker McKenzie Business Briefing, Zurich, 24 February 2016
Presenter, FATCA: Ricadute per avvocati, altri intermediari finanziari e clienti, Convegno Fiscalità e Segreto Bancario: Centro di Studi Bancari, Lugano, 22 October, 2015
Co-presenter, The New EU Succession Regulation – Developments and Implementation in Key Member States, Baker McKenzie Business Briefing, Zurich, 8 September 2015
Co-presenter, Italy's New Voluntary Disclosure Program, Baker McKenzie Business Briefing, Zurich, 10 February 2015
Co-presenter, International Succession Planning and Marital Property, Baker McKenzie Business Briefing, Zurich, 5 February 2015
Co-presenter, Investing in Art, Baker McKenzie Business Briefing, Zurich, 14 October 2014
Presenter, Investimenti Immobiliari negli Stati Uniti, STEP Italia, Milan, March 2014