Avi Guttman

Avi is a cross-border Canada/US tax, trust and estate planning lawyer. Licensed in Ontario, New York and New Jersey, Avi provides tax and estate planning advice to high net-worth individuals and families with a Canadian and US footprint, including US citizens living in Canada, Canadians owning or purchasing US assets, US residents owning Canadian assets, beneficiaries of cross-border trusts and estates. Avi understands the legal and tax complexities involved in the cross-border context and helps craft innovative solutions that minimize tax in both countries, preserve family wealth, and meet his clients’ ultimate estate planning objectives.

Avi’s areas of expertise include IRS compliance for US citizens and residents owning Canadian assets. Avi counsels US clients on the consequences of owning shares in private Canadian companies, including the anti-deferral Controlled Foreign Corporation (“CFC”) and Passive Foreign Investment Company (“PFIC”) rules. Avi also counsels US beneficiaries of Canadian trusts on their US obligations as beneficiaries of foreign trusts, including reporting requirements and the “throwback tax” rules. Avi advises clients on alternate structures to minimize US tax consequences, often revising family structures created without consideration of the US consequences and possible double taxation in Canada and the US. Avi has counseled clients ranging from modest family trusts to multi-million dollar corporate structures.

Avi also has expertise counseling Canadian clients purchasing US real estate for personal use or investment purposes. Avi assists clients in devising the most tax-efficient structure for their investment, including through the use of trusts, partnerships, corporations, or hybrid structures. Avi has assisted with investments ranging from personal use condominiums to multi-million dollar commercial properties. 

As part of his tax and estate planning practice, Avi also assists Canadian estate executors and trustees administer estates with US assets, including preparing and filing of US estate tax returns and probate of US assets. Avi also has experience assisting dual-citizen clients renounce their US citizenship, providing advice on the legal and tax implications of renunciation and guiding clients through the renunciation process. 

Avi received his JD from the Benjamin N. Cardozo School of Law in New York City in 2014, and was admitted to the New Jersey Bar in 2014, the New York Bar in 2015, and the Ontario Bar in 2019. Avi received his Bachelor of Arts degree in psychology from Yeshiva University in New York City in 2010, graduating with honors. Avi is currently in the first year of the CPA Canada In-Depth Tax Program.

When not practicing law, Avi can be found on the basketball court, playing golf, or spending time with his wife and two children.