Counseling Clients on Expatriation: Advising U.S. Citizens, Green Card Holders, and Their Beneficiaries

Alan Winston Granwell, Of Counsel | Holland & Knight

Alan Winston Granwell is Of Counsel in the Washington, D.C. office of Holland & Knight, where he brings more than five decades of deep experience in international taxation to multinational corporations and globally oriented private clients. Known for his substantive grasp of cross-border tax planning, compliance, controversy and transparency initiatives, Mr. Granwell regularly advises on complex international tax matters that span multiple jurisdictions and regulatory regimes.

• Education & Credentials

Mr. Granwell holds an A.B. from Middlebury College, a J.D. from Boston University School of Law, and two LL.M. degrees—one from Boston University in Taxation and another from New York University School of Law. He is admitted to practice in the District of Columbia, Massachusetts, and New York, and is admitted to several federal courts including the U.S. Tax Court and the U.S. Court of Appeals for the Second Circuit.

• Recognition & Leadership

Mr. Granwell’s peers have consistently recognized his excellence in tax law. He has been listed in The Best Lawyers in America for Tax Law for multiple years and featured in Who’s Who Legal for Corporate Tax. His distinguished career also includes recognition by Washington, D.C.’s Super Lawyers magazine. He is a Fellow of the American College of Tax Counsel, reflecting his professional stature in the field.

• Professional Involvement

An active contributor to the broader tax community, Mr. Granwell speaks frequently at major industry and international tax forums. He has presented at events hosted by the American Bar Association Section of Taxation, the International Bar Association, the International Fiscal Association, and the Society of Trust and Estate Practitioners (STEP). Within STEP, he has served as Chair of the Mid-Atlantic Branch and currently serves as Vice-Chair for Programs while contributing regularly to STEP educational initiatives.

• Experience

Mr. Granwell’s practice encompasses advising on international tax planning, transparency initiatives such as the Corporate Transparency Act, FATCA, and the Common Reporting Standard, and representing clients in complex tax compliance and controversy matters. Early in his career he served as International Tax Counsel and Director of the Office of International Tax Affairs at the U.S. Department of the Treasury, where he advised on legislation, regulatory matters and directed the U.S. tax treaty program. Before joining Holland & Knight, he practiced with major Wall Street law firms and boutique international tax practices.

Michael J.A. Karlin, Partner | Holland & Knight

Michael J.A. Karlin is a partner in Holland & Knight’s Century City office, practicing in the firm’s Private Wealth Services and Tax groups. For more than 45 years, he has focused on private client work involving a cross-border element, advising individuals, families, and closely held businesses on tax, estate planning, and business matters spanning multiple jurisdictions. He counsels foreign clients investing or relocating to the U.S. and U.S. clients investing or relocating abroad, with particular emphasis on pre-immigration and expatriation planning and the regulatory and reporting obligations that accompany cross-border activity.

• Education & Credentials

Mr. Karlin earned his M.A. and B.A. in History and Law, with honors, from Cambridge University. He is admitted to the State Bar of California and to practice before the U.S. Tax Court and the U.S. District Court for the Central District of California.

• Recognition & Leadership

Mr. Karlin has been recognized in The Best Lawyers in America for Tax Law (2016–2026) and Trusts and Estates (2026), the Chambers High Net Worth guide for Private Wealth Law – California: Southern (2022–2025), The Legal 500 USA for U.S. Taxes: International Tax (2024), Southern California Super Lawyers for Taxation (2015–present), and Who’s Who Legal: Private Client (2020). He was elected a Fellow of the American College of Tax Counsel in 2020.

• Professional Involvement

Mr. Karlin is a member of the American Bar Association, the Society of Trust and Estates Practitioners (STEP), the USC Gould School of Law Institute on Federal Taxation, and the Los Angeles County Bar Association. He has been actively involved in submitting comments on tax legislation, regulations, and reform, including leading a national group that secured IRS relief on U.S. tax residence rules for noncitizens stranded in the United States during the COVID-19 pandemic.

• Experience

Throughout his career, Mr. Karlin has helped establish corporations, partnerships, and joint ventures in many parts of the world and has worked extensively on foreign and domestic trusts. In recent years, he has assisted numerous taxpayers with the tax and reporting consequences of foreign financial accounts through offshore voluntary disclosures, streamlined disclosures, and other compliance approaches. He is a regular speaker on tax, estate planning, and business issues, and has contributed articles to Tax Notes, Tax Lawyer, Journal of International Taxation, Tax Management International Journal, and Major Tax Planning. Prior to joining Holland & Knight, Mr. Karlin was a founder of a boutique private wealth services law firm in Los Angeles.

Linda Rahal, Managing Shareholder & CEO | Trow & Rahal

Linda Rahal is the Managing Shareholder and CEO of Trow & Rahal, P.C., a boutique firm focused exclusively on immigration and nationality law, where she has practiced since the firm’s founding in 1993. Linda oversees the firm’s business immigration practice, with an emphasis on visas and corporate immigration services for employers; I-9 and compliance matters; global visas; visas for athletes and persons of extraordinary ability; EB-5 and other visa options for investors and entrepreneurs; and citizenship and naturalization. She has built a reputation as a lawyer who goes the distance to deliver winning immigration strategies for both corporate and individual clients.

• Education & Credentials

Linda received her J.D., magna cum laude, from the American University, Washington College of Law, and her B.A., cum laude, in International Relations from Tufts University. She is admitted to practice in the District of Columbia and Maryland.

• Recognition & Leadership

Linda has been repeatedly recognized by her peers for inclusion in The Best Lawyers in America, Super Lawyers, the Legal Elite Readers Poll of SmartCEO magazine, Washingtonian Magazine’s “Top Lawyers,” the Martindale-Hubbell Bar Register of Preeminent Lawyers, and the International Who’s Who of Business Lawyers (Corporate Immigration). She has been recognized by Chambers USA for seven years, where market sources have described her as “highly respected” and peers report she is “excellent.”

• Professional Involvement

Linda is a member of the District of Columbia, Maryland, and American Bar Associations and previously served on the Steering Committee of the Law Practice Management section of the D.C. Bar. She is a long-standing member of the American Immigration Lawyers Association and serves as Chapter President of the International Network of Boutique Law Firms (INBLF) Washington, D.C. chapter as well as a member of the INBLF Board of Directors. Through Trow & Rahal, she is also affiliated with the British-American Business Association and the French-American Chamber of Commerce.

• Experience

For more than three decades, Linda has handled complex immigration matters for corporations and individual clients, including athletes and persons of extraordinary ability. Her practice spans the full range of business immigration needs, from helping employers navigate visa processes and compliance requirements to advising investors, entrepreneurs, and individuals on pathways to U.S. citizenship. An avid athlete herself, Linda has competed in numerous marathons and triathlons, and as part of the CEO Ironman Challenge, she competed in the World Championship Ironman Competition in Kona, Hawaii.

Rosy Lor, Principal, Private Client Services Tax | BDO USA

Rosy Lor is a Principal in BDO USA’s Private Client Services National Tax Office and co-leads the firm’s Private Client Services International Tax Committee. She focuses her practice on cross-border tax matters affecting high-net-worth individuals, with particular emphasis on pre-immigration and expatriation tax planning, cross-border estate and gift tax matters, foreign trusts, tax treaties and other international agreements, and tax controversy.

• Education & Credentials

Rosy earned her LL.M. in Taxation from Georgetown University, her J.D. from American University, Washington College of Law, and her B.A. in Economics and English from Georgetown University.

• Recognition & Leadership

Rosy serves as a member of the AICPA Form 3520 Penalties Task Force and is a frequent speaker at leading tax conferences, including the AICPA & CIMA National Tax Conference and the IRS/George Washington University Law School Annual Institute on Current Issues in International Taxation.

• Professional Involvement

Rosy is a member of the American Bar Association, the District of Columbia Bar Association, and the Society of Trust and Estate Practitioners.

• Experience

Rosy brings extensive cross-border private client tax experience to her practice. Prior to joining BDO, she worked on cross-border private client tax matters at a Big Four accounting firm. Before that, she spent more than 13 years with the IRS Office of Chief Counsel, where she last served as a Senior Technical Reviewer in the IRS Office of Associate Chief Counsel (International). Her combination of government, Big Four, and firm experience allows her to advise high-net-worth individuals and families on the full range of complex international tax issues they encounter.

W. Aaron Hawthorne | Hawthorne Global Tax

W. Aaron Hawthorne is the Principal of Hawthorne Global Tax LLC and a trusted advisor to sophisticated, globally active families. For nearly thirty years, he has guided ultra-wealthy U.S. and multi-national families through the resolution of complex financial and tax issues that protect and grow generational wealth. His practice centers on U.S. transfer and income tax matters, with an emphasis on strategic global tax planning designed to appropriately limit overall global tax exposure for U.S. and non-U.S. families across multiple generations — always with careful attention to the family’s
goals for themselves and their portfolio companies. Aaron works alongside the full advisory team to help families identify their objectives and chart an efficient path to achieve them, while navigating both current and evolving tax and non-tax risks.

• Education & Credentials

Aaron earned his J.D. from the University of Oklahoma College of Law in 1997 and his B.S. in Accounting from George Mason University in 1994. He is recognized by his professional network for his expertise in financial planning and international tax planning, with peer endorsements from colleagues across his career at Andersen and beyond.

• Recognition & Leadership

Aaron is a recognized expert in international tax planning for families and their assets, and a sought-after voice on wealth planning matters at the national and international level. He is a frequent speaker at national and international conferences and webcasts, where he addresses complex wealth planning issues facing globally active families. Within the professional community, he maintains an active presence among leaders in tax, family office, and wealth advisory, regularly engaging with thought leadership on estate tax, portability planning, cross-border estate matters, and the evolving regulatory landscape affecting high-net-worth families.

• Professional Involvement

Aaron has built and maintained a professional network of more than five hundred connections across the tax, legal, accounting, and family office advisory communities, and continues to engage actively with thought leaders at firms including RSM US LLP, Andersen, and across the broader family office ecosystem. Beyond his professional practice, Aaron has demonstrated a long-standing commitment to community service, serving as a foster care parent with Fairfax County Government for a decade, from 2004 to 2014.

• Experience

Aaron founded Hawthorne Global Tax LLC in July 2025 after building his career at some of the most respected names in tax and wealth advisory, including Principal at RSM US LLP, Managing Director at Andersen Tax, Manager in the Personal Financial Services group at PricewaterhouseCoopers, and attorney at Portman & Felser LLP in Savannah, Georgia. His estate and gift tax practice includes planning and ongoing management for many families with net worth in excess of $500 million, including the complex issues that arise when family members reside outside the United States. He has deep experience integrating complex estate and income tax structures, managing the full range of tax compliance needs for wealthy families across multiple entity types and jurisdictions, and addressing federal and state tax controversies, including field audits, appeals, and all versions of the IRS’s Offshore Voluntary Disclosure programs.

SESSION 1 – Citizenship and Resident Status Termination | 1:00pm – 1:30pm

Guide clients through renunciation and relinquishment procedures at U.S. consulates, address Reed Amendment inadmissibility bars, and navigate Form I-407 abandonment plus the eight-of-fifteen-year test for long-term green card holders facing exit tax exposure.

SESSION 2 – §877A Mark-to-Market Exit Tax | 1:30pm – 2:00pm

Identify Covered Expatriates under the tax liability, net worth, and certification tests, apply treaty tie-breaker rules, evaluate the four immigration options for long-term residents, and minimize exit tax exposure through targeted pre-expatriation planning strategies.

BREAK | 2:00pm – 2:10pm

SESSION 3 – §2801 Succession Tax on Covered Gifts and Bequests | 2:10pm – 2:40pm

Apply the 40% succession tax to transfers received by U.S. beneficiaries, distinguish domestic from foreign trust treatment under final regulations, calculate §2801 ratios, and address the rebuttable presumption when expatriates withhold IRS return authorization.

SESSION 4 – Compliance and Remediation | 2:40pm – 3:10pm

Complete Forms 8854, W-8 CE, and 708 filings alongside dual-status returns, then remediate prior noncompliance through IRS Streamlined Filing, Voluntary Disclosure, and Delinquent Information Submission Procedures to cure delinquencies and avoid six-figure penalties.