VIACHESLAV  KUTUZOV, Esq.

VIACHESLAV KUTUZOV is an attorney and counselor-at-law admitted in the State of New York, whose practice concentrates on U.S. and international taxation, commercial law, corporate law, banking and anti-money-laundering regulation. He is the Managing Partner of Kutuzov & Associates, P.C. in New York City, and he serves as a Trustee of the Kutuzov Foundation, a New York non-profit organization. The discussion in this treatise reflects the same body of doctrine and practice that informs his representation of clients across the subject areas treated in the chapters that follow.

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His credentials reflect a deliberate concentration in tax and regulatory practice. He was admitted as an Attorney-at-Law in New York, having previously served the bar and the public in successive capacities: as a Foreign Legal Consultant in New York. He is also an Enrolled Agent admitted to practice before the Internal Revenue Service, a federal credential. He is a member of the American Bar Association, the New York State Bar Association, and the New York City Bar Association.

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He holds a Master of Laws (LL.M.) in Taxation from New York Law School and a first degree in law (J.D.) from the School of Law of HSE University in Moscow. His practice reflects a corresponding fluency in cross-border structuring and the interaction of U.S. law with foreign legal regimes.

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Tax planning and structuring. Mr. Kutuzov advises on U.S. and international taxation, with a particular focus on the international provisions of Subchapter N of the Internal Revenue Code. His tax practice encompasses strategic planning, audit representation, and the preparation of tax opinions and memoranda, together with income-tax-treaty analysis, global supply-chain optimization, multinational structuring, cross-border transactions, and complex tax modeling. On the compliance side, his work spans U.S. federal income and gift-tax returns and audits (Forms 1040, 1041, 1065, and 1120); foreign-information and asset-disclosure filings (Forms 5471, 5472, and 8858); foreign-tax-credit management (Forms 1116 and 1118); Subchapter N filings, including Form 8992 (NCTI/GILTI), Form 8993 (FDDEI), and Form 8975 (country-by-country reporting); business-interest-limitation filings under Section 163(j) (Form 8990); and FBAR and FATCA analysis and reporting.

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Asset protection and confidentiality. Mr. Kutuzov counsels high-net-worth individuals, families, and family offices on asset protection and the confidentiality of assets, designing and implementing domestic and offshore structures — including irrevocable trusts, domestic and foreign asset protection trusts, and private interest foundations — that insulate personal and family wealth from creditor exposure while preserving lawful privacy. His asset protection practice integrates voidable transaction (fraudulent conveyance) analysis under the Uniform Voidable Transactions Act, jurisdictional selection across leading common-law and civil-law centers, and the drafting of protective provisions such as anti-duress, flee, trustee-removal, and trust-protector clauses. On the confidentiality side, he advises on the lawful structuring of beneficial ownership, the interaction of FATCA and the OECD Common Reporting Standard with privacy objectives, and the reporting obligations that govern foreign trusts and foundations, so that legitimate confidentiality is achieved without compromising full compliance with U.S. and international disclosure requirements.

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Corporate and commercial law. His corporate and transactional practice — the body of work most directly reflected in this covers the equity and capital architecture of investment vehicles — classes and series of stock, preferred and carried-interest structures, and the tax classifications that attach to them — together with legal support for mergers and acquisitions, joint ventures, and corporate reorganizations, including strategic counsel on corporate governance and cross-border structuring. He counsels clients on the drafting, negotiation, and execution of commercial agreements in lending and financing, information technology, and services, with an emphasis on secured transactions and negotiable instruments and on creating enforceable obligations that allocate and mitigate risk.

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Banking, AML, and U.S. sanctions. Mr. Kutuzov advises on compliance with the Bank Secrecy Act and the U.S. anti-money-laundering framework, including the regulations of the Office of the Comptroller of the Currency, drawing on experience in financial due diligence, risk assessment and mitigation, and correspondence with financial institutions and regulatory bodies. His sanctions practice addresses the U.S. regulatory framework under the International Emergency Economic Powers Act (IEEPA), CAATSA, and the Ukraine-/Russia-Related Sanctions Regulations (31 C.F.R. Part 589), and includes counterparty screening against the SDN List and application of the 50% Rule, OFAC general- and specific-license requests, compliance-program development, enforcement defense, and counsel on delisting and remediation.