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Education

  • LL.M., New York University School of Law, 1981
  • J.D., Cornell Law School, 1975, Note & Comment Editor, Cornell International Law Review
  • A.B., Yale University, 1970

Bar and Court Admissions

  • Illinois
  • New York
  • District of Columbia
  • District of Columbia Court of Appeals

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

Michael G. Pfeifer

Member, Washington, D.C.
(202) 862-5085
mpfeifer@capdale.com | v-card | PDF
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.

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

  • Vice-Chair, Mid-Atlantic Branch of the Society of Trust and Estate Practitioners (STEP)
  • Adjunct Professor, Georgetown University Law Center

Awards & Rankings

  • Best Lawyers in America, 2010-Present
  • Super Lawyers, Washington, D.C., 2010-Present
  • Chambers USA, Leading Lawyer, 2011, 2013-Present
  • The Legal 500, Recommended, 2014; Leading Lawyer, 2011
  • Expert Guides' Trusts and Estates Practitioners, 2009
  • Martindale-Hubbell AV Preeminent

Recent News

Click here for a full list of media coverage.

Recent Speaking Engagements

Mr. Pfeifer is a 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. 

Below is a list of his most recent presentations.

  • 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
  • Speaker, Video Webcast Segment A: Opening Remarks and Course Overview, American Law Institute (ALI) CLE, International Trust and Estate Planning, October 20, 2014
  • Panelist, Video Webcast Segment B: FATCA and Compliance Issues, 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
  • 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
  • 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, 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
  • 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
  • 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, 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
  • Latest International Tax Developments and News from Washington, D.C., September 23, 2009
  • 21st Annual International Trust & Tax Planning Summit, 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

Click here for a full list of speaking engagements.

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.

Click here for a full list of publications.