Michael G. Pfeifer is a member in Caplin & Drysdale's Washington, D.C. office, joining the firm in 2004.
Services
Mr. Pfeifer's practice focuses on the international tax issues of wealthy individuals, including entertainers and athletes, as well as pre-immigration and expatriation planning, structuring cross-border investments, international deferred compensation and retirement planning. He also handles estate planning matters, including the use of domestic and foreign trusts. He has extensive experience handling tax controversy matters, including voluntary disclosure proceedings.
Highlights
· International tax partner in the National Tax Department of Ernst & Young LLP, where he directed that firm's international private client practice
· Special Assistant to the Associate Chief Counsel (International) at the Internal Revenue Service from 1993-1995, where he directed the legislative project that culminated in the 1996 foreign trust tax changes
· Involved with the Clinton Administration's expatriation tax proposal while at the IRS, including the revisions to the section 1441 withholding tax rules, and the development of the "check-the-box" rules for entity classification
· Tax partner with the London office of Morgan, Lewis & Bockius LLP prior to the IRS, where he concentrated on the international tax issues faced by high net wealth individuals, including authors and entertainers
Professional Activities
· Frequent lecturer on international tax topics before numerous U.S. and foreign professional associations, including ALI-ABA (for which he co-chairs an annual program on international trust and estate planning), ABA Tax Section, International Fiscal Association, Society of Trust and Estate Practitioners, New York State Bar Association, Practicing Law Institute, and the Institute for International Research
· Vice-Chair, the Mid-Atlantic Branch of the Society of Trust and Estate Practitioners (STEP)
· Adjunct professor at the Georgetown University Law Center
Awards & Honors
· Ranked as a Top Lawyer in Tax in the 2011 edition of Chambers USA: Band 4 in Tax - District of Columbia
· Recognized as a leading lawyer in International Tax in the 2011 edition of The Legal 500
· Selected in Legal Media Group's Guide to the World's Leading Trusts and Estates Practitioners in 2009
· Listed in the 2010-2012 editions of The Best Lawyers in America in the category of Trusts and Estates
Recent Publications
Mr. Pfeifer writes frequently on international tax matters. He is also mentioned in major media outlets.
· The State of Expatriation 2011, (August 2011)
· An Overview of the Foreign Account Tax Compliance Act, ABA, Section of Real Property, Trust and Estate Law, 22 Annual Spring Symposia, April 28-29, 2011, Washington, DC (with Oluyemi Ojutiku); originally prepared for NYSBA CLE/STEP, 7 Annual International Estate Planning Institute, March 24-25, 2011, New York City
· The IRS Spotlight on Foreign Athletes and Entertainers, Mondaq Business Briefing (with Lucy Lee, November 7, 2008)
· Foreign Trusts: Everything You Wanted to Know About the Taxation of Foreign Trusts But Were Afraid to Ask, MICPEL: Beyond QDOTs: International Estate Planning for a Flat World (October 29, 2008)
· Curing Non-Compliance: Practical Factors to Consider, American Bar Association Section of Real Property, Trust & Estate Law 19th Annual Spring Symposia (May 1-2, 2008)
Other Professional Affiliations
American Bar Association (Taxation and Real Property, Probate and Trusts Sections)
New York Bar Association (Taxation and Trust and Estates Sections)
District of Columbia Bar Association (Taxation and Estates, Trusts and Probate Sections)
Fellow, American College of Trust and Estate Counsel
Member, Society of Trust and Estate Practitioners
Academician, The International Academy of Estate and Trust Law
Government Experience
Special Assistant to the Associate Chief Counsel, Internal Revenue Service, 1993-1995
U.S. Delegate to the Hague Conference, Convention on the Law Applicable to Agency, U.S. Department of State, 1977