Lucy S. Lee

Lucy S. Lee

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Lucy S. Lee focuses her practice on international tax and estate planning for high-net-worth and global individuals and families. Lucy represents clients on sophisticated matters, including structuring of inbound and outbound businesses and investments, wealth management structures, estate and succession planning (including domestic and foreign trusts), structuring of family offices, pre-immigration tax and expatriation planning, and U.S. tax compliance in the cross-border context. Lucy also represents taxpayers in audits and controversies with the Internal Revenue Service and with foreign tax authorities under Mutual Agreement Procedures.

In addition to working with individuals and families, Lucy advises global funds and foreign financial institutions on U.S. tax compliance and reporting obligations, including FATCA and CRS. She works with entrepreneurs and their businesses in improving financial efficiency through proactive planning and management of tax attributes (including managing anti-deferral regimes, foreign tax credits, taxable nexus, and bilateral tax treaties), and develops risk management programs to avoid unrecoverable tax costs.

Concentrations

  • Domestic and International Estate Planning
  • Income Tax Planning for Entrepreneurs, Privately-held Businesses, and Global Executives
  • Income Tax Planning for Global Funds and Principals
  • Structuring of Inbound and Outbound Investments
  • Domestic and Foreign Trust Planning and Governance
  • Pre-immigration Planning for High-net-worth Individuals and Families
  • Expatriation of U.S. Individuals
  • Tax Compliance in the Cross-border Context Including FATCA and CRS
  • U.S. Tax and Compliance of Foreign Trusts and Beneficiaries
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Capabilities

Experience

  • Provided international tax structuring advice to U.S.-based multinational corporations on their offshore business and investment activities, corporate reorganizations, interests in CFCs and PFICs, funding of offshore operations, application of income tax treaties, permanent establishments, sourcing, and withholding of income, foreign tax credit planning and developing proactive compliance and risk management strategies.°
  • Advised private clients on management of cross-border assets and investments, tax and succession planning through gifts to family structures and domestic and foreign trusts, and U.S. tax compliance in the cross-border context, including voluntary disclosure of offshore assets and financial accounts.°
  • Advised settlors, beneficiaries, and fiduciaries of foreign trusts on U.S. tax implications and developed strategies for repatriation of accumulated income and curing prior U.S. tax noncompliance.°
  • Provided tax and investment structuring advice to U.S.-based private equity funds and their principals with operations and investors around the world.°
  • Developed comprehensive income tax and estate planning structures for non-U.S. principals of large private equity funds and sovereign funds entering the U.S. market or creating U.S. nexus.°
  • Provided pre-immigration tax advice to non-U.S. individuals and EB-5 investors, including managing of tax residency, effective use of bilateral tax treaties, wealth management structures for worldwide assets, income tax efficient and estate blocker structures for U.S. situs assets (including real estate), and use of trusts in asset protection and tax planning. °
  • Provided expatriation tax and immigration advice to U.S. citizens and long-term green card holders, developed strategies for minimizing the impact of the expatriation tax, and assisted in the preparation of the IRS Expatriation Statement.°
  • Provided international tax advice to international athletes and entertainers on their cross-border professional activities, endorsements and sponsorships and U.S. tax compliance.°
  • Advised the Korean tax authorities, Korean financial institutions and Korean investment and banking associations on U.S. tax compliance obligations including disclosures under FATCA.°
  • Represented corporate and individual taxpayers in controversies with the IRS (and foreign tax authorities), including civil audits and competent authority proceedings.°
  • Worked with large private foundations in developing tax-efficient cross-border investment strategies and U.S. tax compliance programs.°

°The above representations were handled by Ms. Lee prior to her joining Greenberg Traurig, LLP.

  • Ernst & Young (EY)
    • Partner, 2014-2015
    • Manager, 2000-2007
  • International Tax Counsel, GE, 2012-2014

Recognition & Leadership

  • Listed, The Legal 500 United States, Tax, 2012
  • Recognized, Corporate Tax Directors Handbook, “Leading Lawyer – Tax”
  • Recognized, National Tax Service of Korea, “Outstanding Contribution to the Deepening of Cooperation between the Korea and USA Tax Administrations”
  • Society of Trust & Estate Practitioners (STEP), 2001-Present
  • International Bar Association, 2014-Present
  • American Bar Association, Tax Section, 2001-Present
  • NY State Bar Association, 2002-Present
  • D.C. Bar Association, 2006-Present
  • International Association of Korean Lawyers, 2012-Present
  • Korean-American Bar Association of Greater Washington (Executive Board), 2009-Present
  • Council of Korean Americans (Pro Bono Counsel), 2017-Present
  • Korean Americans in Action (Pro Bono Counsel), 2017-Present
  • The Toa Nafasi Project (Board Member), 2017-Present

Credentials

Education
  • LL.M., Taxation, Georgetown University Law Center, 2005
  • J.D., The George Washington University Law School, 2001
  • B.A., University of Virginia, 1998
Admissions
  • District of Columbia
  • New York
Admitted in the District of Columbia and New York. Not admitted in Virginia. Practice limited to federal tax practice.
Languages
  • Korean, Fluent
  • Spanish, Basic Conversation