Michael G. Pfeifer

Michael G. Pfeifer: Attorney with Caplin & Drysdale, Chartered AV stamp icon
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Attorney Awards

Biography

Michael G. Pfeifer is a Member in Caplin & Drysdale's Washington, D.C., office.

Services

Mr. Pfeifer's practice focuses on the international tax issues of wealthy individuals, including entertainers and athletes. He counsels clients on planning for pre-immigration and expatriation, as well as on structuring cross-border investments. Moreover, Mr. Pfeifer advises high-net-worth individuals on estate planning matters, including the use of domestic and foreign trusts, and tax controversy matters such as voluntary disclosure proceedings.

Government Experience

Special Assistant, Associate Chief Counsel, Internal Revenue Service, 1993-1995

U.S. Delegate, Hague Conference, Convention on the Law Applicable to Agency, U.S. Department of State, 1977

Highlights

•International tax partner in the National Tax Department of a multinational professional services firm, 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 “mark-to-market” expatriation tax proposal while at the IRS, as well as revisions to the section 1441 withholding tax rules, and the development of the check-the-box rules for entity classification; and
•Tax Partner with the London office of a global law firm prior to the IRS, where he concentrated on the international tax issues faced by high net wealth individuals, including authors and entertainers.

Awards & Rankings

Chambers High Net Worth Guide, Private Wealth Law, D.C. and USA: Eastern Region, 2016-Present
Chambers USA, 2011, 2013-2016
The Legal 500, Leading Lawyer, 2011; Recommended, 2014, 2017-Present
The Legal 500, Top-Tier Firm, Tax - US Taxes - Contentious, 2010, 2015-Present
Best Lawyers in America, 2010-Present
Super Lawyers, Washington, D.C., 2010-Present
Expert Guides' Trusts and Estates Practitioners, 2009
Martindale-Hubbell AV Preeminent
Legal Week's Private Client Global Elite, 2017- Present
The Washingtonian, Top Lawyer, 2017-Present

Recent Publications

Mr. Pfeifer writes frequently on international tax matters. He is also mentioned in major media outlets.

Below is a list of Mr. Pfeifer's most recent publications.

• IRS Weapons Against Aggressive Tax Planning, with Sae Jin Yoon, Trusts & Trustees, February 19, 2019
• IRS Adds Foreign Trust Information Reporting to Compliance Campaign Program, with Arielle M. Borsos, Victor A. Jaramillo, Kirsten Burmester, and Dianne C. Mehany, Caplin & Drysdale Client Alert, June 1, 2018

(republished in Global Tax Weekly )

• Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets, with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Arielle M. Borsos, Caplin & Drysdale Client Alert, November 6, 2017
• Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership, with Scott D. Michel, H. David Rosenbloom, Kirsten Burmester, and J. Clark Armitage, Caplin & Drysdale Client Alert, April 5, 2016
• The Final OECD BEPS Tome Has Arrived, with H. David Rosenbloom, Patricia Gimbel Lewis, J. Clark Armitage, and Peter A. Barnes, Caplin & Drysdale Client Alert, October 8, 2015
• The Current State of Expatriation, ALI CLE Estate Planning Course Materials Journal, December 1, 2014
• The Current State of Expatriation, A Guide to International Estate Planning, American Bar Association, 2nd Ed., December 31, 2013
• FATCA: An Overview of Its Scope and Application to Non-U.S. Entities Chapter, with Dianne C. Mehany, The International Comparative Legal Guide to: Private Client 2014, 3rd Edition, December 23, 2013
• FATCA Reporting - Are Trusts and Trustees Caught in the Net?, with Dianne C. Mehany, Financier Worldwide, July 1, 2013
• District of Columbia Alters Treatment of Municipal Bond Interest, with Beth Shapiro Kaufman, Caplin & Drysdale Client Alert, March 26, 2013
• Professional Golfer Sergio Garcia to Owe More Taxes on Endorsement Income, with Mark D. Allison and H. David Rosenbloom, Caplin & Drysdale Client Alert, March 15, 2013
• Fiscal Cliff Averted: Tax Consequences for High-Net-Worth Individuals, with Kirsten Burmester, Beth Shapiro Kaufman, and James E. Salles, Caplin & Drysdale Client Alert, January 7, 2013
• An Overview of the Foreign Account Tax Compliance Act, American Bar Association, 22nd Annual Spring Symposia, April 28, 2011
• President Obama Signs Bill on Tax Cut Extensions, with Beth Shapiro Kaufman, Caplin & Drysdale Client Alert, December 17, 2010
• The Final State of Expatriation? - Part I, Mondaq Business Briefing, October 1, 2009
• The Final State of Expatriation? - Part II, Mondaq Business Briefing, September 28, 2009
• The IRS Spotlight on Foreign Athletes and Entertainers, Mondaq Business Briefing, 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 23, 2008
• Curing Non-Compliance: Practical Factors to Consider in the United States, International Bar Association, International Wealth Transfer Pricing Conference, March 3, 2008
• Tax Alert, Caplin & Drysdale, February 1, 2005

Recent Speaking Engagements

Mr. Pfeifer is a frequent lecturer on international tax topics before numerous U.S. and foreign professional associations, including ALI-CLE (for which he created and co-chaired an annual program on international trust and estate planning for 21 years), 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.

Below is a list of his most recent presentations.

•Panelist, Outbound Planning for U.S. Individuals, ALI CLE International Trust and Estate Planning, November 2, 2018
•Panelist, Outbound Planning for U.S. Investors, ALI CLE International Trust and Estate Planning, November 2, 2018
•Panelist, UK and U.S. Tax Update, Mourtant International Trusts & Private Client Conference, October 5, 2018
•Speaker, Comparing Civil Law and Common Law Responses to Aggressive Tax Planning, The International Academy of Estate and Trust Law, 2018 Annual Meeting, May 23, 2018
•Speaker, Expatriation, ALI CLE International Trust and Estate Planning, November 10, 2017
•Tax and Immigration Planning and Compliance for High Net Worth Individuals Acquiring U.S. Citizenship, Green Cards and Expatriating, Bloomberg BNA, June 12, 2017
•Panelist, Practical and Technical Issues for the Immigrating Client: Income Tax, Transfer Tax and Immigration, Society of Trust and Estate Practitioners ( STEP ), May 4, 2017
•Panelist, Life is Short: Buy the Shoes and Plan for Your Inheritance, ABA Section of Taxation, IBA Taxes Committee, and IFA-USA Branch, April 5, 2017
•Speaker, Expatriation, ALI CLE International Trust and Estate Planning, October 28, 2016
•Speaker, Practical Advice for Clients with Foreign Trusts and Foreign Business Interests, ALI CLE International Trust and Estate Planning Program, October 27, 2016
•Chair, Tax and Immigration Planning and Compliance for High Net Worth Individuals Acquiring U.S. Citizenship, Green Cards and Expatriating, Bloomberg BNA, June 13, 2016
•Chair, Planning for Changes of Residence and Nationality, Society of Trust and Estate Practitioners ( STEP ), May 5, 2016
•Speaker, Michael Pfeifer to Speak at STEP Event, Mid - Atlantic STEP, January 14, 2016
•Panelist, Green Cards and Expatriation: The Immigration, Tax Planning and Tax Compliance Aspects, Bloomberg BNA, November 12, 2015
•Speaker, VIDEO WEBCAST SEGMENT D: Expatriation, ALI CLE International Trust and Estate Planning, August 14, 2015
•Speaker, Opening Remarks and Course Overview, ALI CLE International Trust and Estate Planning, August 13, 2015
•Panelist, VIDEO WEBCAST SEGMENT B: FATCA and Compliance Issues, ALI CLE International Trust and Estate Planning, August 13, 2015
•Speaker, Planning With Regard to a Change of U.S. Status, STEP USA and STEP Los Angeles, The Inaugural STEP USA Conference: Pacific Rim Today, June 4, 2015
•Speaker, Practicing in a Transparent World, STEP USA and STEP Los Angeles, The Inaugural STEP USA Conference: Pacific Rim Today, June 4, 2015
•Panelist, Ethics and Tax Compliance - The Morality of Tax Avoidance, The International Academy of Estate and Trust Law, 2015 Annual Meeting, May 17, 2015
•Panelist, Planning Strategies for the Lives & Taxes of the Mobile Working Rich, 15th Annual Tax Planning Strategies - U.S. and Europe, April 15, 2015
•Speaker, Starting the New Year Off Right: A Potpourri of Current Developments Including an Update on FATCA, OVDP, and the New IRS Streamlined Procedure, Society of Trust and Estate Practitioners (STEP), Mid-Atlantic February Live Event, February 3, 2015
•Panelist, Option 1 - U.S., Canadian Tax Developments, Society of Trust and Estate Practioners (STEP), 2014 Global Congress, November 7, 2014
•Speaker, Video Webcast Segment D: Expatriation, American Law Institute (ALI) CLE, International Trust and Estate Planning, October 21, 2014
•Panelist, Video Webcast Segment B: FATCA and Compliance Issues, American Law Institute (ALI) CLE, International Trust and Estate Planning, October 20, 2014
•Speaker, Video Webcast Segment A: Opening Remarks and Course Overview, American Law Institute (ALI) CLE, International Trust and Estate Planning, October 20, 2014
•Speaker, FATCA and Trusts: What You Need To Know and How To Prepare for the July 1 Deadline, American Law Institute (ALI) CLE, Webcast/Telephone Seminar, April 17, 2014
•Speaker, Collateral Damage - When Governments Target Advisors Because They Can't - Or Won't - Reach Principals, 2014 Private Client Forum Americas Conference, February 5, 2014
•Speaker, Practical Briefings: Residence and Citizenship, Institute for International Research, 22nd International Tax and Trust Summit, November 19, 2013
•Speaker, Course 2A: Record Renunciation of U.S. Citizenships; Tax Consequences, Life Changes & Passports, University of San Diego School of Law, Procopio International Tax Institute Conference, October 24, 2013
•Speaker, Expatriation, American Law Institute (ALI) CLE, International Trust and Estate Planning, October 11, 2013
•Speaker, U.S. Activities of Foreigners & Tax Treaties: Planning for Inbound U.S. Investments Through Foreign Trusts, American Bar Association, 2013 Joint Fall Meeting, September 20, 2013
•Speaker, Expatriation for U.S. Tax Purposes, Transnational Taxation Network New York 2013, May 6, 2013
•Speaker, OVDI: Where Are We and How Did We Get There, The Society of Trust and Estate Practitioners (STEP), Mid-Atlantic Chapter Meeting, December 3, 2012
•Top 10 Things You Need to Know When There is Something Foreign in Your Estate Plan, American College of Trust and Estate Counsel (ACTEC), 2012 Fall Meeting Professional Program, October 20, 2012
•Speaker, Expatriation, American Law Institute CLE, 2012 International Trust and Estate Planning Course, August 24, 2012
•Panelist, Inside the Beltway Report: Update on Recent International Tax Enforcement Developments for Private Client Practitioners and Advisors, Society of Trust and Estate Practitioners (STEP), 5th Annual Pacific Rim Conference, May 3, 2012
•Speaker, Immigration and Emigration, Practising Law Institute (PLI), International Estate & Tax Planning 2012 Conference, April 23, 2012
•Panelist, 12 TIEAs later: Are things any clearer or at least more transparent?, International Bar Association, 17th Annual International Wealth Transfer Practice Conference, March 5, 2012
•Speaker, The U.S. Expatriation Tax, Society of Trust & Estate Practitioners (STEP), January 25, 2012
•Presenter, The Foreign Tax Compliance Act ( FATCA ) or is it Forget about the Carrot Approach - The US Opts for Swinging the Stick, Florida Bar and Florida Institute of CPAs (FICPA), 30th Annual International Tax Conference, January 19, 2012
•International Bar Association Annual Conference, October 30, 2011
•Speaker, The Nuts and Bolts of Expatriation - What Is the Process?, Society of Trust & Estate Practitioners - NY, October 18, 2011
•Speaker, Expatriation, American Law Institute (ALI) CLE, American Bar Association, 14th Annual Course of Study for Counselors to Foreign and U.S. Clients, August 19, 2011
•Chair, Recap of Day One, American Law Institute (ALI) CLE, American Bar Association, 14th Annual Course of Study for Counselors to Foreign and U.S. Clients, August 19, 2011
•Chair, Opening Remarks and Course Overview, American Law Institute (ALI) CLE, American Bar Association, 14th Annual Course of Study for Counselors to Foreign and U.S. Clients, August 18, 2011
•Panelist, Income and Transfer Tax Planning Group (Part 2): I Will Survive - Hot Topics in Income and Transfer Tax Planning, American Bar Association, 22nd Annual Spring Symposia, April 29, 2011
•Speaker, Issues in International Trust Taxation, New York State Bar Association (NYSBA) CLE and Society of Trust and Estate Practitioners (STEP), 7th Annual International Estate Planning Institute, March 25, 2011
•Speaker, FATCA and Lates Reporting Developments in U.S. - Offshore Transactions, New York State Bar Association (NYSBA) CLE and Society of Trust and Estate Practitioners (STEP), 7th Annual International Estate Planning Institute, March 24, 2011
•Chair, Planning Chair Recap of Day One, American Law Institute (ALI) CLE and American Bar Association, 13th Annual Advanced ALI-ABA Course of Study for Counselors to Foreign and U.S. Clients, August 20, 2010
•Speaker, Expatriation, American Law Institute (ALI) CLE and American Bar Association, 13th Annual Advanced ALI-ABA Course of Study for Counselors to Foreign and U.S. Clients, August 20, 2010
•Speaker, Developments in Offshore Tax Compliance (Practioner View), American Law Institute (ALI) CLE and American Bar Association, 13th Annual Advanced ALI-ABA Course of Study for Counselors to Foreign and U.S. Clients, August 19, 2010
•13th Annual Advanced ALI-ABA Course of Study for Counselors to Foreign and U.S. Clients, August 19, 2010
•School of Law 2009 Procopio International Tax Institute, October 19, 2009
•Chair, Twelfth Annual Advanced ALI-ABA Course of Study for Counselors to Foreign and U.S. Clients, American Law Institute (ALI), American Bar Association, October 1, 2009
•21st Annual International Trust & Tax Planning Summit, September 23, 2009
•Latest International Tax Developments and News from Washington, D.C., September 23, 2009
•The Current State of Expatriation, June 3, 2008
•Panelist, Grandma Died with a Cook Islands Trust: Now What?, American Bar Association, 19th Annual Spring Symposia, May 1, 2008
•Taxation of Artists and Sportsmen, October 11, 2007
•Speaker, International Trust and Estate Planning, 8th Annual Advanced ALI-ABA Course of Study for Counselors to Foreign & U.S. Clients, August 25, 2005

Recent News

•Michael Pfeifer Named a Leading Practitioner by Who's Who Legal, Who's Who Legal, December 3, 2018
•ALI CLE Bestows Lifetime Achievement Award Upon Michael Pfeifer, ALI CLE, November 2, 2018
•Caplin & Drysdale Improves Ranking in 2019 Best Lawyers in America , August 15, 2018
•Caplin & Drysdale Attorneys Advance in Chambers Ranking for Private Wealth Law, Chambers High Net Worth Guide, July 23, 2018
•2018 Legal 500 Distinguishes 18 Caplin & Drysdale Attorneys, Firm Renews Top-Tier Firm Ranking for Tax Controversy, The Legal 500, May 31, 2018
•18 Caplin & Drysdale Attorneys Recognized by Super Lawyers in D.C., April 23, 2018
•Chambers Lists Caplin Lawyers as Leaders in Private Wealth Law, Chambers High Net Worth Guide, September 15, 2017
•Michael Pfeifer Comments on ALI CLE International Estate Planning Conference, American Law Institute Continuing Legal Education, September 13, 2017
•Caplin & Drysdale Earns Top Ranking in 2018 Best Lawyers in America , August 15, 2017
•7 Caplin & Drysdale Lawyers Listed as Leaders in Their Field by Expert Guides, Expert Guides, July 25, 2017
•Michael Pfeifer Listed Among Legal Week's Private Client Global Elite, Legal Week, June 26, 2017
•18 Caplin & Drysdale Lawyers Recognized in 2017 Legal 500 Ranking, The Legal 500, June 2, 2017
•Caplin & Drysdale Lawyers Listed Among D.C.'s Most Prominent Practitioners, Super Lawyers, April 27, 2017
•Best Lawyers in America Lists 18 Caplin & Drysdale Attorneys, U.S. News & World Report, August 15, 2016
•Caplin & Drysdale Attorneys Listed as Leaders in Their Field for Private Wealth Law, Chambers High Net Worth Guide, June 24, 2016
•Caplin & Drysdale Listed Among Top Lawyers for Tax, Bankruptcy, Estate Planning and Political Law, Chambers USA, June 1, 2016
•Super Lawyers Recognizes Caplin & Drysdale Lawyers from Several Practice Areas, Super Lawyers, April 26, 2016
•Michael Pfeifer Comments on U.S. Expatriation Numbers, KNX Money Hour, September 14, 2015
•Clients and Peers Distinguish Caplin & Drysdale in Chambers' Rankings, Chambers USA, May 19, 2015
•Michael Pfeifer Comments on the Issuance of U.S. Guidance on Expatriate Tax Status, Worldwide Tax Daily, May 6, 2015
•Super Lawyers Lists Caplin & Drysdale Lawyers, Caplin & Drysdale, April 23, 2015
•Michael Pfeifer and Kirsten Burmester Comment on Tax Returns of Americans Living Abroad Under Scrutiny, MainStreet, November 10, 2014
•Caplin & Drysdale Lawyers Earn Best Lawyers Ranking, August 21, 2014
•Caplin & Drysdale Earns Top Honors in 2014 Chambers USA, Chambers USA, May 28, 2014
•Bloomberg Quotes Michael Pfeifer: Trusts May Be Financial Institutions Under FATCA, Bloomberg BNA's Financial Planning Journal, May 20, 2014
•Michael Pfeifer Comments on the Impact of FATCA on Trust Companies, Bloomberg BNA's Financial Planning Journal, May 20, 2014
•The Washington Post Lists Caplin & Drysdale Attorneys Among the Top Attorneys in D.C., The Washington Post, April 30, 2014
•Tax Notes Today Quotes Michael Pfeifer: U.S. Expatriations Likely Won't Increase Further in Future, Practitioner Argues, Tax Notes Today, October 25, 2013
•19 Caplin & Drysdale Attorneys Achieve Best Lawyers in America Ranking, U.S. News & World Report, October 21, 2013
•Scott Michel and Michael Pfeifer Selected for Legal Tax Advisory Board, June 10, 2013
•14 Caplin & Drysdale Attorneys Recognized in Chambers USA 2013, Chambers USA, May 29, 2013
•Wealthy Americans Target of New IRS Initiative, Caplin & Drysdale, May 7, 2013
•The Sovereign Investor Quotes Michael Pfeifer on Puerto Rico's Tax Incentives, The Sovereign Investor, May 2, 2013
•Super Lawyers Lists Nineteen Caplin & Drysdale Attorneys, Super Lawyers, April 29, 2013
•The New York Times Quotes Michael Pfeifer on Puerto Rico's Tax Incentives, The New York Times, March 26, 2013
•Caplin & Drysdale Lawyers Alert International Athletes to Beware Endorsement Tax Issues, Caplin & Drysdale, March 18, 2013
•Michael Pfeifer Speaks with Tax Notes on Foreign Citizenships For Sale , Tax Notes, March 5, 2013
•Michael Pfeifer Quoted in CNBC article, Chasing Saverin's Winnings Is a Losing Battle, CNBC, May 17, 2012
•Michael Pfeifer Quoted in CNBC article, Facebook Co-Founder Saverin Renounces Citizenship, CNBC, May 11, 2012
•2012 Tax Directors Handbook Ranks Caplin & Drysdale as Leading Tax Law Firm, Tax Directors Handbook, December 1, 2011
•The Best Lawyers in America Ranks 19 Caplin & Drysdale Attorneys as Leaders in Their Field, U.S. News & World Report, September 1, 2011
•Chambers and Legal 500 Recognize Caplin & Drysdale in 2011 Top Rankings, Chambers USA / The Legal 500, June 16, 2011
•19 Caplin & Drysdale Attorneys Named Best Lawyers in America, U.S. News & World Report, August 4, 2010
•IRS Is Said to Broaden UBS Inquiry, The New York Times, February 2, 2009

Areas of Practice (3)

  • Private Client
  • International Tax
  • Tax Controversies

Education & Credentials

Contact Information:
(202) 862-5085  Phone
www.caplindrysdale.com
University Attended:
Yale University, A.B., 1970
Law School Attended:
Cornell Law School, J.D., Note & Comment Editor, Cornell International Law Review, 1975; New York University School of Law, LL.M., 1981
Year of First Admission:
1975
Admission:
District of Columbia Court of Appeals; 1975, Illinois; 1978, New York; 1994, District of Columbia
Memberships:

Other Professional Affiliations

Member, American Bar Association, Taxation and Real Property, Trust and Estate Law Sections

Member, New York Bar Association, Taxation and Trust and Estates Sections

Member, 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

Professional Activities

•Vice-Chair, Mid-Atlantic Branch of the Society of Trust and Estate Practitioners (STEP)
•Visiting Lecturer, University of Miami School of Law, Graduate Tax Program

ISLN:
904454459

Peer Reviews

5.0/5.0
A Martindale-Hubbell Peer Rating reflects a combination of achieving a Very High General Ethical Standards rating and a Legal Ability numerical rating.

*Peer Reviews provided before April 15, 2008 are not displayed.

Documents (13)

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