Christopher R. Callahan

Practice Areas

As Chair of the International Taxation & Wealth Planning Practice, Christopher provides wealth management and international tax planning advice to high-net-worth clients, funds and businesses. In recognition of his dedication to developing cutting-edge tax strategies for his clients, Christopher has been named as one of the leading tax attorneys in Florida by Chambers USA.

In his practice, he handles a full range of international taxation and wealth issues, including foreign pension planning and compliance for individuals and active companies with U.S. employees; domestic and international tax planning for partnerships (e.g., private equity and real estate funds); domestic and international income tax planning, including Subpart F, GILTI and FDII planning, for closely-held corporations; advice regarding U.S. income and estate tax treaties; tax planning for non-resident individuals, including wealth and estate planning (e.g., trust planning), FIRPTA withholding and pre-immigration tax planning; formation of foreign grantor trusts by foreign settlors (particularly redomiciling Panama Foundations to the United States); tax compliance and disclosure matters (e.g., submissions to the Streamlined Offshore Procedures, Delinquent FBAR Procedures, delinquent International Information Return Procedures, etc.); tax planning for non-resident executives of U.S. companies (e.g., how to minimize exposure to U.S. estate tax regarding their ownership of company stock and stock options as well as other U.S. situs assets such as U.S. portfolios and U.S. real estate); and cross-border employment tax planning for publicly traded corporations.

Career

Prior to joining Fox Rothschild, Christopher was a member of a Chambers-rated international taxation group at a Miami-based boutique taxation law firm. In addition, prior to practicing law, Christopher worked in the Basketball Operations Department of the Philadelphia 76ers of the National Basketball Association (NBA).

Professional Memberships

American Bar Association | Florida State Bar Association | Florida Bar Tax Section, International Tax Division, Co-Director | Florida Bar Real Property Probate and Trust Law Section, International Estate and Trust Tax Planning Subcommittee, Chair | International Fiscal Association | Irish American Bar Association of Florida | Lexwork International | New York State Bar Association | Society of Trusts and Estates (STEP), Gold Coast Florida Chapter, Educational Programming, Director

Education