Samuel N. Bazylenko

Overview

Samuel is an attorney in Gunster's Private Wealth Services practice based in the firm's Miami office. He advises both domestic and international individuals, families, and closely held businesses on a broad range of U.S. federal income, gift, and estate tax matters arising from cross-border investments, business operations, and wealth planning objectives.

Samuel's practice focuses on structuring international investments and business activities in a tax-efficient manner, with particular experience assisting foreign investors in navigating the U.S. tax implications of acquiring, holding, and disposing of U.S. assets. He regularly counsels clients on the Foreign Investment in Real Property Tax Act (FIRPTA) and related withholding and reporting obligations associated with U.S. real estate transactions. He also advises individuals and families on pre-immigration tax planning strategies designed to mitigate unintended tax consequences before establishing U.S. residency.

Known for his detail-oriented and pragmatic approach, Samuel works closely with clients to develop tailored solutions that align legal, tax, and business considerations. He combines technical tax knowledge with a practical understanding of commercial objectives to help clients confidently navigate complex domestic and international tax issues.

Prior to joining Gunster, Samuel was a member of the Mergers & Acquisitions Tax Services practice at a Big Four accounting firm, where he advised clients on sophisticated international tax matters arising from cross-border transactions and multinational operations. His experience included analyzing controlled foreign corporation (CFC) issues, Subpart F income, tested income regimes, and other complex aspects of the U.S. international tax framework.

While earning his LL.M. in Taxation, Samuel served as an extern to the United States Tax Court in Washington, D.C., where he gained firsthand insight into federal tax litigation and judicial decision-making.