Elliott H. Murray

Biography

Elliott Murray is head of the US Tax and Wealth Management practice in Geneva and is a partner in the Firm's International Tax and Global Wealth Management practice groups. Elliott has significant experience assisting high net worth individuals and families with US and international tax, wealth planning, and regulatory and family governance matters.

Elliott is a member of the Firm’s EMEA Wealth Management Steering Committee, a co-editor of the Global Wealth Management practice group’s quarterly Private Wealth Newsletter, and has lectured at LLM programs on US tax and FATCA/CRS issues. Elliott has been listed in ALM Private Client Global Elite, Ones to Watch for 2017, 2018, 2019, and 2021.

While at the University of Texas School of Law, he completed an internship (stage) at the European Court of Justice as a Dean Acheson Legal Intern.

Practice Focus

Elliott has a particular focus on US income and transfer tax planning for US and non-US private clients and frequently advises individuals and families in connection with cross-border investments, real estate, closely-held businesses, and trust and estate planning. He also works with clients on tax compliance, expatriation, and citizenship and residency matters and with non-US financial institutions on US tax and regulatory issues, including advising on the FATCA and the Common Reporting Standard.

Professional Associations and Memberships

Swiss-American Chamber of Commerce – Member
International Bar Association / Private Client Tax – Member
Texas Bar Association, Tax Section & Real Property, Trust, and Estate Planning Section – Member
Society of Trust and Estate Practitioners (STEP) – Affiliate Member

Admissions

Texas~United States (2010)

Education

University of Texas School of Law (J.D., with Honors) (2010)
University of North Carolina at Chapel Hill (B.A. History, with Distinction) (2005)

Languages

English
French

Previous Offices

Miami

Publications

Co-author, “IRS Guidance Reduces Reporting on Foreign Pension and Other Savings Plans But Does Not Clarify Income Tax Liabilities,” Journal of International Taxation, February 2021

Co-author, “Updates on Beneficial Ownership Reporting in the United States,” Baker McKenzie Client Alert, January 2021

Co-author, “US beneficiaries may claim withholding tax credit for foreign nongrantor trust distributions,” Baker McKenzie Client Alert, May 2020

Co-author, “Implementation of the Current Withholding Tax in France: the French exception is gone!” 47 Intertax, Issue 3, 2019

Co-author, “IRS Issues Final Regulations Protecting Current Large Gifts from Future Taxation,” Baker McKenzie Client Alert, November 2019

Co-author, “US Senate Ratifies Protocols to US Tax Treaties with Japan, Luxembourg, Spain, and Switzerland,” Baker McKenzie Tax News and Developments, August 2019

Co-author, “IRS Begins Notifying Owners of Cryptocurrency of Potential Failures to Report Income and Pay Taxes,” Baker McKenzie Client Alert, August 2019

Co-author, “IRS and State Department Set to Issue Passport Revocation Notices (“Letter 6152”),” Baker McKenzie Client Alert, July 2019

Co-author, “IRS Concedes Position on Creditability of French Social Charges,” Baker McKenzie Client Alert, June 2019

Co-author, “IRS to Obtain US Bank Information on Finnish Residents with US Bank Accounts,” Baker McKenzie Client Alert, May 2019

Co-author, “Split decisions: District courts and claims court differ on IRS discretion in FBAR penalties,” Baker McKenzie Private Wealth Newsletter, March 2019

Co-author, “Individual US Taxpayers Eligible for GILTI Deduction if Electing Corporate Tax Treatment, Baker McKenzie Client Alert, March 2019

Co-author, “Vive La (Withholding Tax) Revolution: Special Issues for US Citizens and Residents in France,” Journal of Taxation, February 2019

Author, “IRS and Treasury Release Proposed Foreign Partner Sales Regulations,” Baker McKenzie Tax News and Developments, January 2019

Co-author, “Updates to donor disclosure rules in the US and UK,” Baker McKenzie Private Wealth Newsletter, December 2018

Co-author, “End of Offshore Voluntary Disclosure Program,” Baker McKenzie Client Alert, March 2018

Co-author, “IRS Releases Notice on US Passport Revocation and Limitation Process,” Baker McKenzie Client Alert, January 2018

Co-author, “The Tax Cuts and Jobs Act: Congress Passes a Major Tax Bill for First Time in Thirty Years,” Baker McKenzie Client Alert, 20 December 2017

Presentations

Co-presenter, “US Presidential Tax Policy,” Baker McKenzie Switzerland Webinar, 10 November 2020

Co-presenter, “US/French Cross-Border Succession Planning,” Baker McKenzie Switzerland Webinar, 6 October 2020

Co-presenter, “Extraterritorial Effect of US and EU Reporting Obligations,” Baker McKenzie Switzerland Webinar, 22 September 2020

Co-presenter, “Commodity Trading Hubs – Tax and Transfer Pricing Issues,” Baker McKenzie Geneva Trading Company Webinar Series, 14 July 2020

Co-presenter, “Wealth Management: Trends, Tax Increases and Outlook,” Baker McKenzie Regional Webinar Series: Recovery & Renewal: EMEA Tax Issues, 7 July 2020

Co-presenter, “CRS Compliance & Audits, EU DAC6, UBO Registers & EU AMLD,” Baker McKenzie Switzerland Webinar, 25 June 2020

Co-presenter, “Stranded Persons and Tax Planning during and after the COVID-19 Crisis,” Baker McKenzie Switzerland Webinar, 28 May 2020

Co-presenter, “Family Offices as A Tool for Successful Family Business Successions,” Baker McKenzie Business Briefing, Zurich, 21 January 2020 & Geneva, 4 February 2020

Co-presenter, “On a tightrope: Reconciling fiduciary duties with ethical investments,” Baker McKenzie Business Briefing, Geneva, 10 September 2019 & Zurich, 2 October 2019

Co-presenter, “Avoid An Own Goal: Planning Considerations for Athletes,” Baker McKenzie Business Briefing, Geneva, 22 May 2019

Co-presenter, “Exchange of Information and Mandatory Disclosure Rules: Compliance & Disputes,” Baker McKenzie Workshop, Geneva, 5 April 2019

Co-presenter, “Wealth Management Workshop,” Baker McKenzie Workshop, Barcelona, 11 March 2019

Co-presenter, “Danger Ahead! Cones on the road, tolls and potholes – Residence and Citizenship: What are the wider tax, succession and property implications,” Baker McKenzie Business Briefing, Geneva, 5 December 2018

Co-presenter, “Charitable Giving: Tax and Legal Issues in the US, UK, Switzerland, and Italy,” Baker McKenzie Business Briefing, Geneva, 9 October 2018

Co-presenter, “Round Table Discussion on US Tax Reform and Implications for Swiss Business and Subsidiaries,” Baker McKenzie Business Briefing, Geneva, 27 September 2018

Co-presenter, “US Tax Reform Workshop: Planning Opportunities and Pitfalls,” Baker McKenzie Workshop, Geneva, 2 March 2018

Presenter, “Impact of US Tax Reform on high net worth individuals and their investments,” Baker McKenzie Business Briefing, Geneva, 15 January 2018