As an international tax lawyer, Christina Santana Hammervold focuses her practice on counseling families, entrepreneurs, trustees and financial institutions on a wide range of international and domestic tax-planning matters. Christina’s clients range from entrepreneurs wishing to establish family offices, to established global families managing their own wealth in the billions, to some of the world’s most renowned trust companies. She has extensive experience with a wide range of global family structures and prides herself on delivering efficient, strategic and results-oriented solutions for her clients.
Christina has broad experience in assisting clients (most often multinationals and the families that own them) navigate the United States legal system, generally from a tax perspective, but also with respect to the various other considerations that arise when families (or select family members) move to or invest in the United States. She works with clients to design and implement holistic financial and estate planning structures that solve for global tax challenges, wealth transfer and succession considerations, asset protection, privacy needs, and corporate governance and family office compliance issues. Christina is versatile and resolute on providing innovative, yet practical, legal strategies.
Christina has significant experience in working with families in Latin American, Europe, the Middle East, Africa, Hong Kong, Southeast Asia and, of course, the United States. She considers herself fortunate to work with some of the most successful businesspeople, former politicians and celebrities in these regions and the trust companies and private banks that act for them. Christina, and those that work with her on the International Private Client team, are truly dedicated to their clients and it shows in the highly service-oriented advice and product they deliver.
Christina is proficient in Spanish.
- Representation of numerous global families seeking to succeed assets to younger US generations in a tax-efficient manner (commonly referred to as “foreign grantor trust planning”). During such representation, Christina has advised on all tax aspects that arise throughout the chronological stages of foreign grantor trust planning, to include managing the application (whether a current or future issue) of the “accumulation distribution” regime (DNI/UNI), the “controlled foreign corporation” regime and the “passive foreign investment company” regime.
- Representation of high-net-worth US and non-US families in their worldwide organizational and tax structures designed to reduce the incidence of worldwide income, capital, gift, estate and generation-skipping taxes.
- Representation of numerous non-US families immigrating to the United States (commonly referred to as “pre-immigration planning”), to include providing tax and family succession advice related to the various considerations that arise when moving to the United States.
- Representation of numerous US families emigrating from the United States to ensure that such a move is done in the most tax-efficient manner possible (commonly referred to as “expatriation planning”).
- Representation of numerous non-US families with respect to tax and other legal considerations implicated by their acquisition and ownership of various United States assets, to include private residences, commercial real estate, cars, boats, private planes and a variety of US businesses (ranging in industry, e.g., hospitality, chemicals, technology, energy, health care and real estate).
- Representation of families with respect to the “institutionalization” of their wealth over multiple generations and jurisdictions, including the establishment of private trust companies, family offices and related structures facilitating the particular family’s needs.
- Significant experience managing “global reporting” for multinational families, to include classification, registration and reporting under both the Foreign Account Tax Compliance Act (commonly known as “FATCA”) and the OECD’s Common Reporting Standard (commonly known as “CRS”). Christina also has broad experience advising on intergovernmental requests vis-à-vis various Tax Information Exchange Agreements with the United States, as well as common US tax reporting for multinational families (e.g., Form 3520s, Form 8938s, Form 5472s, Form 1040s / 1040NRs, foreign grantor and nongrantor trust beneficiary statements, FBARs and the various other reporting obligations that arise when global families interact with the United States).
- Representation of a European-based registered trust company in connection with its establishment of a US trust company and the strategic development and implementation of its US-based products designed for LATAM families.
- Representation of a non-US family in its acquisition of a majority stake in a non-US consortium invested in an approximately US$2 billion acquisition and redevelopment project of a trophy property in one of the top markets in the United States.
- Representation of US families investing outside of the United States and implementation of planning involving “controlled foreign corporations” and “passive foreign investment companies”.
- Representation of private equity and hedge funds organized in the Cayman Islands in connection with acquisitions of US businesses, restructurings and various other business issues.
- Representation of a Fortune Global 100 company in its acquisition of a water treatment division conducting business in 15 countries.
- Representation of a Fortune Global 100 company in its disposition of a global manufacturing division conducting business in over 25 countries, coordinating a cross-border legal team of over 20 lawyers.