Shudan Zhou

Norton Rose Fulbright US LLP

New York
United States
T:+1 212 318 3086
New York
United States
T:+1 212 318 3086

Related services and key industries


Shudan counsels high net worth individuals, trustees, and financial institutions on the US tax implications of wealth transfer strategies, with an emphasis on international income and estate tax planning. She has substantial experience advising clients on all aspects of FATCA and CRS as well as various withholding tax and disclosure regimes. Shudan frequently advises clients on the US tax consequences of expatriation from and immigration to the United States, and of US inbound and outbound investment structures. Shudan also advises on the creation, administration and governance of offshore trust structures.

As a trusted advisor to her clients, Shudan is often called upon to collaborate with other departments at the firm to provide multidisciplinary advice, including investment fund formation, cross-border family office structuring, US tax issues related to US shareholders' offshore investments and foreign investors' inbound investment structuring. 

Professional experience

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JD, Boston University School of Law
MA, Shanghai International Studies University
BA, Sun Yat-sen University

  • Connecticut State Bar
  • New York State Bar
  • Advised a leading European family with respect to optimizing the US tax treatment of its US descendants, focusing on the potential impact of the foreign trust anti-deferral regime (the throwback tax) and the foreign corporation anti-deferral regime (the CFC and PFIC rules) as well as the interaction between the two regimes.
  • Advised a Canadian-US-UK family with respect to certain US tax impacts of an existing offshore wealth structure on the US beneficiaries, including the potential US tax classifications of certain offshore foundations, potential US tax treatment of the foundations' US beneficiaries upon the death of the founder as well as "exit strategies" for restructuring various foundations and offshore companies.
  • Advised a multibillionaire US-Chinese family on their cross-border family office structuring as well as the formation and operation of a family investment fund.
  • Advised the US founders of multiple multinational biotech companies with major operations in China with respect to the founders' wealth holding structures prior to the companies' initial public offerings on the Hong Kong Stock Exchange.
  • Advised a US-Chinese family on the restructuring of their existing offshore trusts to address US tax issues in connection with CFC- and PFIC-attribution through foreign trusts, as well as subsequent restructuring in connection with the family's and their business's global headquarters' proposed relocation to Switzerland.
  • Lawdragon 500X – The Next Generation 2003
  • New York Metro Super Lawyers Rising Star, Thomson Reuters, 2020 - 2022
  • New England Super Lawyers Rising Star, Thomson Reuters, 2016 - 2018
  • Ones to Watch, Private Client and Global Elite, The American Lawyer and Legal Week, 2017 - 2019
  • "Conversion between Grantor and Nongrantor Trust Status: Tax Benefit Evaluation and Potential Pitfalls", Strafford webinar, February 2023
  • "Here Today, Gone Tomorrow - Tax Issues Affecting Temporary Residents," ABA Tax Section 2022 Fall Meeting, October 2022
  • "Advanced Trust Planning for U.S.-Chinese Families with Global Assets," STEP LA Webinar, March 2021
  • "Recent Developments in U.S.-China Tax and Trust Planning - The Onshore v. Offshore Debate", STEP Boston Webinar, November 2020
  • "U.S.-China Planning for High Net Worth Individuals (Case Studies)," STEP Mid-Atlantic Webinar, May 2020