James Guadiana

James A. Guadiana

Partner
New York: 212.880.6308
Fax 212.682.0200

Education

LLM, 1967
New York University School of Law
JD, 1966
Fordham University School of Law

Bar Admissions

New York, 1966

Overview

Jim Guadiana has extensive experience as tax advisor to a number of public corporations listed on the London, Hong Kong, and Toronto stock exchanges. Jim has served as advisor to public and privately-held multinational companies and investment firms with regard to their operations and investments in the United States. Jim is respected domestically and internationally as an expert in recognizing and resolving novel and complex tax issues in domestic and cross-border investments in a myriad of fields. Jim also has represented clients before U.S. tax agencies and U.S. tax courts.

Recently, Jim has:

  • Served as U.S. tax counsel to one of the world's largest commodities companies in its pre-IPO reorganization and IPO, advising it on complex U.S. tax and executive compensation matters
  • Served as tax advisor for U.S. real estate development projects, providing both pre- and post-formation tax planning, and structuring investment vehicles to optimize after-tax returns for foreign investors
  • Advised clients on the establishment of transfer pricing policies, and assisted clients in implementing beneficial cost-sharing and other arrangements
  • Advised a number of public and private companies on preservation of net operating losses
  • Provided planning on various cross-border sales of physical commodities and related hedging transactions
  • Advised both issuers and investment banks regarding the treatment of foreign corporations as to their status, or avoidance of status, as passive foreign investment companies ("PFICs")
  • Structured multinational executive compensation programs to achieve optimum tax benefits for employers and employees in multiple jurisdictions
  • Advised client on the tax aspects of transfers of proprietary technology (including patents)
  • Advised multinational families with regard to their global investments, business activities, and U.S. tax compliance requirements

Representative Work

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Recognition

Super Lawyers—Leading lawyer in tax (2013-2015)

Martindale-Hubbell’s Peer Review Ratings, AV Preeminent Rated Lawyer

Who's Who in American Law, 2010-2013

Insights

FBAR and FATCA: Fear and Loathing

Presenter, Tax Executives Institute

Memberships and Affiliations

  • Committee on U.S. Activities of Foreign Taxpayers, Tax Section, New York State Bar Association
  • International Fiscal Association (U.S. Branch)
  • The Tax Club
  • International Tax Institute