James Gifford

James Gifford

Associate
Baker & McKenzie Zurich
Not admitted to practice law in this jurisdiction

Biography

James Gifford is a native of California, but has been based in Zurich since 2013. His past experiences include practicing at midsize tax boutique law firms in Canada and Switzerland and working as an in-house wealth planner for Rothschild Trust. James was previously an associate in our Palo Alto office.

Practice Focus

James’s practice focuses on the US aspects of international tax planning for families and individuals and on advising the fiduciaries and banks that serve this clientele. James is also experienced in resolving personal and estate tax disputes with the US Internal Revenue Service (IRS). As a member of the California bar, James is knowledgeable on community property and California specific tax issues.

Representative Legal Matters

  • Audited the wealth holding structures comprised of numerous trusts and underlying companies worth more than USD 1 billion of an extended South American family.

  • Obtained the removal of US tax penalties on a foreign estate valued at over USD 100 million through an IRS Appeals proceeding.

  • Acted for a former US ambassador in making a voluntary disclosure to the US Internal Revenue Service.

  • Conducted a review of all foreign grantor trusts with potential US beneficiary tax exposure under the 2017 tax reform for a large trust company.

  • Assisted the founder of a Silicon Valley start-up in obtaining tax-free treatment of the proceeds from selling interests in the company worth over USD 10 million.

Professional Associations and Memberships

  • STEP - Affiliate member

Admissions

  • California~United States (2008)

Education

  • New York University School of Law (LLM Taxation) (2012)
  • University of California at Berkeley (Boalt Hall) (JD) (2008)
  • University of California at San Diego (BA Political Science / Political Theory) (2005)

Languages

  • English
  • German
  • Spanish

Previous Offices

  • Palo Alto

Panel Speaker, “Holding Company Jurisdictions”, Steuerkonferenz 2017, Institute of Financial Services Zug, May 2017

Speaker, Hearing on Proposed Treasury Regulations under Internal Revenue Code section 1411, April 2013

Co-author, “Americans Living Abroad Face Double Taxation in 2013,” Tax Notes, Feb 2013

Co-author, “Why Canadian Residents May Soon Owe U.S. Tax,” Journal of International Taxation, December 2012

Co-author, “The Corporate Residency Proposals,” North America Tax News and Developments, April 2009