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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, 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 and 2013 editions of Chambers USA: Wealth Management: Eastern Region (Nationwide)
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 2010-2013 editions of The Best Lawyers in America in the category of Trusts and Estates
Listed in the 2010-2013 editions of Super Lawyers
AV rated by Martindale-Hubbell

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)