Ryan M. Wilson

Partner

Ryan Wilson uses his creativity and experience to develop efficient solutions for even the most complex tax issues.  He is also a member of the firm’s Management Committee.

Ryan is a partner in the Tax Department, and is chair of the International Practice Group.  He advises local, mainland and international clients on a wide range of federal and Hawai`i tax issues.  He has particular expertise in the tax treatment of real estate investment, leasing and development.  He also handles federal and Hawai`i tax audits, as well as section 1031 like-kind exchange transactions.

Before attending law school, Ryan was a Latin instructor at the University of Illinois, and an English teacher in Gunma-ken, Japan.  He is proficient in written and spoken Japanese.

Real Estate Tax

  • Handles deferred and reverse section 1031 exchanges of Hawai`i and mainland real estate
  • Counsels real estate investors on structuring real estate holdings to maximize their eligibility for capital gain or like-kind exchange treatment
  • Structures leases to maximize tax benefits for the lessor and lessee, and to obtain or avoid treatment as a section 467 rental agreement
  • Advises on the conveyance tax, general excise tax, HARPTA withholding and bulk sale aspects of Hawai`i real estate transactions

Partnership Tax

  • Drafts allocation and distribution provisions of partnership and operating agreements to implement the partners’ tax and economic goals
  • Advises partners on tax-efficient methods of forming, operating and liquidating partnerships and LLCs
  • Counsels clients on how to minimize taxes on the sale or redemption of partnership and LLC interests
  • Handles the tax aspects of partnership and LLC mergers and divisions

Corporate Tax

  • Advises clients on the tax consequences of formation and operation of corporations
  • Helps corporations evaluate the benefits of making S elections, REIT elections, or filing consolidated returns
  • Advises shareholders about the most tax-efficient manner of extracting value from their corporations
  • Handles the tax aspects of corporate mergers, reorganizations and separations

International Tax

  • Advises international individuals and corporations on the most tax-efficient manner of structuring their U.S. investments and operations
  • Helps international clients minimize the U.S. withholding and tax burdens when repatriating their U.S. income
  • Counsels international individuals on how to minimize U.S. gift and estate taxes on their U.S. investments

Tax Audits, Appeals and Letter Rulings

  • Represents clients in federal and Hawai`i tax audits
  • Negotiates settlements of federal and Hawai`i tax assessments
  • Assists clients with voluntary disclosures of unpaid federal and Hawai`i taxes
  • Handles federal and Hawai`i private letter ruling requests

Awards

  • Super Lawyers® Rising Star, Tax, 2015 and 2016
  • Best Lawyers in America® for Tax Law, 2015 and 2016
  • Chicago-Kent Law Review, Executive Articles Editor
  • Honors Scholarship (tuition waiver and stipend)

Education

  • J.D. (2006), Chicago-Kent College of Law, with high honors, Order of the Coif
  • M.A. Classics (2001), University of Illinois at Urbana-Champaign
  • B.A. Philosophy (1999), University of Illinois at Urbana-Champaign, magna cum laude

Admissions

  • Hawai`i State Bar (2006)
  • United States District Court for the District of Hawai`i
  • United States Tax Court
  • Illinois State Bar (2008)

Memberships

  • Hawai`i State Bar Association (Tax Section, Former Chair)
  • American Bar Association (Tax Section)
  • The Chamber of Commerce of Hawai`i (Tax Committee, Former Chair)