Private Client
International Tax
Tax Controversies
Articles
Speeches
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
District of Columbia
New York
Illinois
American Bar Association (Sections on Taxation and Real Property, Probate and Trusts) New York Bar Association (Sections on Taxation and Trusts and Estates) District of Columbia Bar Association (Sections on Taxation and Estates, Trusts and Probate) Fellow of the American College of Trust and Estate Counsel Member of the Society of Trust and Estate Practitioners
Special Assistant to the Associate Chief Counsel (International), 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
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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
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International tax partner in the National Tax Department of Ernst & Young LLP, where he directed that firm’s international private client practice
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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
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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
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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
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Frequent lecturer on international tax topics before numerous professional associations, including ALI-ABA (for which he co-chairs an annual program on international trust and estate planning), Practicing Law Institute, Institute for International Research, and the International Fiscal Association
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Vice-Chair, the Mid-Atlantic Branch of the Society of Trust and Estate Practitioners (STEP)
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Fellow, American College of Trust and Estate Counsel
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Adjunct professor at the Georgetown University Law Center
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Has participated on panels sponsored by the American Bar Association, the New York State Bar Association and STEP
Awards and Honors
Selected Recent Publications
Mr. Pfeifer writes frequently on international tax matters. He is also mentioned in major media outlets.
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The Final State of Expatriation?, Practicing Law Institute: International Estate and Tax Planning 2009 (June 2, 2009)
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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)
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