Meet The CARFtools Team
Paul Foster Millen
Paul Foster Millen (NYU School of Law, J.D. '05, LL.M in Tax '18) is the founder and principal of Millen Tax & Legal GmbH in Zürich, Switzerland. He specialises in the US and international tax and regulatory consequences of cross-border income flows and asset holdings. Amongst his matters of specific expertise are CARF/DAC8 and CRS/FATCA. Since 2007, he is member in good standing of the New York State Bar Association.
CARF Publications
In addition to co-authoring the five-part Old Tricks for New Dogs series in Tax Notes International with Peter, he has individually published the following articles related to CARF–
• Article: CARF’s Impact on the Crypto Marketplace: An Equal and Opposite Reaction?, Intertax, Volume 54, Issue 3 (2026) pp. 183 – 190
• Book chapter: Year in Review (2024), The American Bar Association (ABA), author of the chapter on Europe, addressing inter alia OECD's CARF and the EU's DAC8
CARF Presentations
Paul regularly presents on CARF. You can find some clips below from a October 2025 presentation for Academy & Finance conducted in Geneva.
• Watch Paul explain the key dissimilarities between CARF and CRS and why they are necessary
Professional background
• Deloitte AG, Zürich, Switzerland
Tax Department - October 2011 - January 2017
• Cahill Gordon & Reindel LLP, New York, NY
Associate (Litigation Department) - October 2005 - February 2010
Educational background
• New York University School of Law, New York, NY LL.M in Tax - May 2018
• New York University School of Law, New York, NY J.D., cum laude - May 2005
• Duke University, Durham, NC B.A. in History and Economics, minor in Japanese - May 1997
Peter Cotorceanu
Peter A. Cotorceanu (LL.B. (Hons), Victoria University of Wellington; J.D. with Distinction, Duke University School of Law; LL.M. in Tax, New York University School of Law) is co-founder of CARFtools.com and founder and CEO of GATCA & Trusts Compliance Associates LLC (G&TCA), which has provided consulting and online implementation tools for CRS and FATCA to the financial and fiduciary industries since 2014. Peter is one of a very small number of practitioners who have implemented an automatic exchange of information regime from the inside: as Global Head of Product Management for Trusts and Foundations at UBS, he led the bank’s global FATCA implementation for its trust and foundation business before returning to private practice in 2014.
He has practised law for more than forty years across three jurisdictions. Before heading UBS’s Product Management for Trusts and Foundations, Peter was Head of Wealth Structuring Consulting for ultra-high-net-worth clients at UBS, an international estate planning and US tax lawyer at Baker & McKenzie in Zurich, a law professor at Washburn University School of Law in Kansas, and a trusts and estates practitioner and litigator in Virginia and Maryland. He is a Registered Trust and Estate Practitioner (TEP) and holds active bar admissions in New Zealand, Virginia and Maryland, including the United States Court of Appeals for the Fourth Circuit.
Peter has written and spoken on FATCA and CRS since 2013 and about CARF since its publication. His analysis of the United States as an emerging tax haven has been quoted in the Financial Times, the Washington Post, Bloomberg Businessweek, the Guardian, the Los Angeles Times, the Neue Zürcher Zeitung, the Frankfurter Allgemeine, and in Oliver Bullough’s book Moneyland.
CARF publications
With Paul Millen, Peter is co-author of the five-part Old Tricks for New Dogs series on the Crypto-Asset Reporting Framework in Tax Notes International, the first detailed practitioner analysis of CARF against the CRS rules it was built on:
• Old Tricks for New Dogs PartI: The OECD’s Cryptoasset Reporting Framework, TaxNotes International, 16 October 2023
• Part II: The OECD’s Cryptoasset Reporting Framework, 8 April 2024
• Part III: Identifying Crypto Beneficial Owners, 30 September 2024
• Part IV: CARF’s Reporting Obligations, 4 November 2024
• Part V: CARF Enforcement and Compliance, 9 December 2024
All five parts are available in full on CARFtools.com.
CRS and FATCA publications
Book chapters
• The Common Reporting Standard, chapter 35 of A Guide to International Estate Planning (American Bar Association, 3rd ed., 2026)
• FATCA and the Trust Industry, chapter 9 of the LexisNexis Guide to FATCA Implementation (3rd ed., 2015)
Selected articles
• A Fiduciary’s Survival Guide: Advice on the Upcoming FATCA Responsible Officer Certifications, STEP Journal, November 2018 (with Paul Millen)
• The Small Print: When and Why FATCA Responsible Officers of Model-1 IGA Sponsors Have IRS Certification Obligations, STEP Journal, March 2018 (with Paul Millen)
• Countdown to July: Are US Corporate Trustees About to be Ambushed by FATCA?, STEP Journal, December 2017 (with Paul Millen)
• Hiding in Plain Sight: How Non-U.S. Persons Can Legally Avoid Reporting Under Both FATCA and GATCA, Trusts & Trustees, Vol. 21, Issue 10, 2015
• The Swiss Role in FATCA, STEP Journal, June 2014 (with Quan Nguyen)
• FATCA and Underlying Companies: Pin the Tail on the Elephant, 142 Tax Notes 957, 3 March 2014
• FATCA and Offshore Trusts: A Second Bite of the Elephant, 140 Tax Notes 1007, 2 September 2013
• FATCA and Offshore Trusts: The First Nibble, 139 Tax Notes 409, 22 April 2013
Earlier work on US expatriation tax, foreign trust rules and international estate planning appeared in the Journal of International Taxation, Tax Planning International Review and the New York State Bar Association Trusts and Estates Law Section Newsletter.
In the press
Peter’s work on offshore structures, financial privacy and the United States as a tax haven has been cited in:
• Moneyland: The Inside Story of the Crooks and Kleptocrats Who Rule the World, Oliver Bullough (St. Martin’s Press, 2019)
• Financial Times (March 2016, December 2016, April 2017)
• Washington Post, Los Angeles Times, the Guardian, Vox and S&P Global (April 2016, Panama Papers coverage)
• Bloomberg Businessweek, The World’s Favorite New Tax Haven is the United States (January 2016)
• Forbes, Tax Notes, Law360
• Neue Zürcher Zeitung, Frankfurter Allgemeine, Handelszeitung, Basler Zeitung, Finews
Speaking
Since 2014 Peter has given more than seventy conference presentations and workshops on FATCA, CRS and CARF for the fiduciary and financial industries, including:
• TransWorld Compliance, CARF: Basic Architecture and Comparisons and Contrasts with CRS, December 2025
• STEP conferences and branches in Asia (Singapore, Hong Kong), the Caribbean (Cayman, Barbados, St Lucia, Bermuda, The Bahamas), Latin America (Panama, Mexico), Switzerland (Zurich, Geneva, Lugano), the Global Congress (Amsterdam) and the STEP/NYSBA International Estate Planning Institute (New York)
• Academy & Finance seminars in Zurich, Geneva, Luxembourg, Malta, Cyprus, Jersey, Guernsey, Bermuda, the Bahamas, Cayman and Hong Kong
• FATCA Responsible Officer and CRS implementation bootcamps in Zurich, Geneva and Bermuda, co-presented with Paul Millen
• Singapore Trustees Association annual conferences and FATCA implementation workshops
• Transcontinental Trusts (Geneva, Bermuda), Offshore Alert (London, Miami), the International Tax Planning Association (London), the International Bar Association (London), the Practising Law Institute (New York), the University of San Diego Procopio International Tax Institute, and the South Dakota Trust Association
Before 2014 Peter led UBS’s global training on FATCA, foreign grantor trusts and wealth planning for the bank’s wealth planning consultants and trust company staff across its offices worldwide.
Professional background
• CARFtools.com, co-founder with Paul Millen
• GATCA & Trusts Compliance Associates LLC, founder and CEO, August 2014 to present
• Anaford AG Attorneys at Law, Zurich, Of Counsel, CRS and FATCA compliance and cross-border estate and tax planning, 2014 to 2020
• UBS AG, Zurich, Executive Director; Global Head of Product Management, Trusts and Foundations (2010 to 2014); previously Head of Wealth Structuring Consulting, UHNW Clients, 2007 to 2010
• Baker & McKenzie, Zurich, international estate planning, US tax and multi-jurisdictional succession planning, 2004 to 2007
• Washburn University School of Law, Topeka, Kansas, Associate Professor of Law, 1999 to 2004; instrumental in the Kansas Legislature’s adoption of the Uniform Trust Code and testified before both houses on trust legislation
• College of William & Mary School of Law, Adjunct Professor, 1990 to 1999
• Knicely and Cotorceanu, P.C., Williamsburg, Virginia, trust and estate planning, estate and gift tax, trust administration and litigation, 1988 to 1999
• Earlier practice in trusts and estates and litigation in Annapolis and Baltimore, Maryland, 1982 to 1988
Bar admissions and professionalmemberships
• New Zealand High Court (Barrister and Solicitor)
• Virginia Supreme Court; United States Court of Appeals for the Fourth Circuit; United States District Court for the Eastern District of Virginia
• Maryland Court of Appeals; United States District Court for the District of Maryland (Federal Trial Bar); United States Bankruptcy Court for the District of Maryland
• Society of Trust and Estate Practitioners, Registered TEP, since 2005
• Virginia State Bar, since 1988 (Board of Governors, Trusts and Estates Section, 1991 to 1998)
All bar admissions are active.
Education
• LL.M. (Tax), New York University School of Law, 2012
• J.D., With Distinction, Duke University School of Law, 1982
• LL.B. (Honours), Victoria University of Wellington, 1980
Disclaimer: This article is intended for general informational purposes only and does not constitute legal or regulatory advice. Parties should seek qualified legal counsel regarding their specific obligations under the applicable CARF/DAC8 regulations.