Partner
and access,
Carol Fitzsimmons practices in a wide range of domestic and international tax areas, including guiding Canadian and other non-U.S. clients on U.S. tax matters. She regularly counsels clients on U.S. tax and corporate issues related to business operations, mergers and acquisitions, and sales; U.S. tax issues in domestic and foreign private and public offerings; U.S. tax considerations related to investments in U.S. real estate; “inversion” structures; hybrid entity arrangements; business expansion into the United States from foreign jurisdictions; advantageous business structures for U.S. tax and estate planning purposes; U.S. tax consequences of relinquishment or renunciation of U.S. citizenship or lawful permanent resident ("green card") status; and U.S. tax issues affecting U.S. taxpayers resident abroad, including compliance with U.S. tax requirements, issues under the Foreign Account Tax Compliance Act (FATCA), and the U.S. anti-deferral tax regimes such as the controlled foreign corporation (CFC) and passive foreign investment company (PFIC) rules. She also advises clients on cross-border estate planning matters. Carol’s clients include public and privately held businesses, business owners and investors, high-net-worth individuals and executives of multinational corporations. Carol is a frequent speaker on U.S. tax law, especially in the cross-border context and as it affects businesses and individuals in Canada and internationally. Carol is a member of the Board of Directors of Hodgson Russ. Carol exclusively practices U.S. law and is admitted to practice in New York.