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Ruby Banipal

International Advisor and Council (Canada)

T: + 1 714 876 5804
F: + 1 773 439 2787
E: ruby@legamaro.com

About Ruby

Ruby Banipal is International Advisor and Council based out of Canada. She provides international tax planning and implementation solutions for ultra-high-net-worth clients, their investment vehicles and related structures – principally those who are globally active, hold concentrated wealth with multi-jurisdictional assets, business and reach, and are acting for their own accounts or are the foreign financial institutions catering to and advising such wealth.

Ruby regularly works with cross-disciplinary teams in implementing international structures and investment strategies for US and non-US individuals and their families.

Ruby counsels clients on the tax implications that arise when cash, property, businesses or transactions cross borders. In this capacity, Ruby advises foreign clients on the US income, estate and gift tax consequences of alternative inbound investment structures while utilizing income, estate and gift tax treaties to minimize tax and regulatory burdens. Often, Ruby's clients are multi-generational families that span multiple jurisdictions, requiring an in-depth understanding of tax laws worldwide.

Previously, Ruby was a member of the global private client practice at DLA Piper and was based out of DLA’s Chicago, Seattle, and Hong Kong offices.  In this capacity, Ruby worked regularly with counsel in Asia, Europe, Canada and Latin America to service clients that are interested in making cross-border investments. Prior to that, she was an International Tax Consultant with a Big Four accounting firm.  She also has prior experience working with the Internal Revenue Service Office of Chief Counsel and the Department of Justice, California Attorney General’s Office (Business/Tax Section).

Experience

  • Inbound planning for global families acquiring oil and gas, commercial real estate and other business interests in the United States with a view toward creative reduction of overall tax

  • Domestic (US) and foreign private trust companies for families that own and manage global businesses, real estate and investment portfolios to ensure that control is retained at the highest level and that the assets could be passed down for the benefit of the future generations

  • Non-US banking institutions, trust companies, fund administrators, investment managers and the like regarding compliance with the Foreign Account Tax Compliance Act (FATCA)

  • Non-US banking institutions regarding compliance with the US-Swiss voluntary disclosure program

  • Non-US trust companies with respect to their fiduciary and other planning needs, particularly involving trusts where United States beneficiaries are either currently or expected to be within the pool of beneficiaries

  • High-net-worth 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, including the establishment of foreign trusts for the benefit of US family members

  • Development and implementation of creative techniques involving tax-wise charitable giving, family limited partnerships, and limited liability companies, and techniques designed to reduce the imposition of US estate, gift and generation-skipping taxes

  • Representing buyers and sellers in acquisitions of privately held companies, including providing pre-transaction advice and council, due diligence, structuring, drafting, negotiating, and tax planning

  • Representing clients in various IRS Voluntary Disclosure Programs for offshore, foreign and domestic assets, accounts investments and income, including the Streamlined Foreign Offshore Procedures

Credentials

Admissions

  • California and Illinois

Speaking Engagements

  • Transnational Tax Network (TTN), New York (2018) "New Tax Law: Paradigmatic shift in planning inbound to the US”

  • Transnational Tax Network (TTN), Mexico City (2018) “New US real estate holding structures”

  • Society of Trusts & Estates Practitioners (STEP) - various presentations

Education

  • L.L.M. (Tax), Northwestern University School of Law  (2011)

  • J.D. (Emphasis in Taxation), Chapman University School of Law (2010)

  • B.A., Psychology, Simon Fraser University (2007), cum laude