Noam is a U.S. tax lawyer (Registered Foreign Lawyer, New York qualified) who has been based in Hong Kong since 2014. He advises individuals, trustees, and financial institutions on U.S. and International tax matters, with expertise in private client work. His practice focuses on trusts with U.S. beneficiaries, pre‑immigration and pre‑expatriation planning, and designing holding structures for U.S. real estate, equities, funds, and other assets. He also advises on U.S. tax reporting and withholding obligations, FATCA and information exchange standards, FBAR compliance, voluntary disclosure procedures, Qualified and Nonqualified Intermediaries, and other cross‑border tax issues.
Noam’s tax law publications have appeared in prominent journals, including the Yale Journal of International Law, Harvard Business Law Review, Columbia Journal of Tax Law, Virginia Tax Review, and the American Journal of Comparative Law. His publications have been cited in reports by the World Bank, the International Monetary Fund, the European Commission, and the United Nations Development Programme.
Noam is a full member of the Society of Trust and Estate Practitioners (STEP). He serves on the Executive Committee of the Hong Kong branch of the International Fiscal Association (IFA). He is also the honorary secretary of the Joint Liaison Committee on Taxation, which facilitates dialogue between tax practitioners and the Hong Kong government. He holds a Doctor of Juridical Science (S.J.D.) from Harvard Law School, where he was awarded the John M. Olin Prize for the best paper in law and economics.
Key Experience
- Advised private clients on succession planning, wills, trusts, and estates from a U.S. tax perspective.
- Advised on the settlement of foreign grantor trusts, including trust deeds, letters of wishes, and trust structures.
- Provided advice on foreign non-grantor trusts to minimise adverse tax implications, including CFC, PFIC, and throwback rules.
- Advised on U.S. tax reporting obligations, FBAR compliance, and entity classification elections.
- Advised non-U.S. persons considering relocation or immigration to the United States, and U.S. persons considering expatriation.
- Advised on U.S. tax issues relating to offering circulars and disclosures, cross-border restructurings and transactions, tax treaty matters, and withholding obligations of non-U.S. financial institutions.
- Advised on holding structures for U.S. investments, including U.S. real estate, U.S. funds, and U.S. equities.
- Assisted clients with voluntary disclosures, penalty abatement, and other U.S. tax matters.
Career History
Foreign Registered Lawyer (New York Qualified), Mishcon de Reya LLP
Associate Professor of Law, Chinese University of Hong Kong
Registered Foreign Lawyer (New York Qualified), Baker McKenzie
Harvard Law School, Doctor of Juridical Science (S.J.D.)
Harvard Law School, Master of Laws (LL.M.) (requirements fulfilled, degree waived)
Tel Aviv University, Bachelor of Laws (LL.B.)
Tel Aviv University, Bachelor of Arts (B.A.) in Accounting
Articles and Publications
- “Congress-Proof” International Tax Reforms”, 101 Tulane Law Review (May 2025)
- “Ending the Crypto Tax Haven”, 15 Harvard Business Law Review 171 (March 2025)
- “Chinese Companies in Tax Havens”, Journal of International Economic Law, Volume 27, Issue 3 (September 2024) (with Jingyi Wang)
- “U.S. Tax Classification and Treatment of Non-U.S. Private Foundations”, Trusts & Trustees 1, Volume 30, Issue 6 (July 2024) (with Lyubomir Georgiev & Christiana Desrosiers)
- “Formal vs. Informal Voluntary Disclosure Policies”, The American Journal of Comparative Law, Volume 72, Issue 1 (Spring 2024) (with Viktoria Wöhrer & Pierce Lai)
- “Targeting Tax Avoidance Enablers”, 13 UC Irvine Law Review 1355 (December 2023) (with Zachary Marcone)
- “Closing the “Shell Bank” Loophole”, 64 Virginia Journal of International Law, Vol. 64, No. 1 (September 2023) (with Zachary Marcone)
- “The International Response to the U.S. Tax Haven”, 48 Yale Journal of International Law 177 (July 2023) (with Zachary Marcone)