Michael G. Pfeifer is a member in Caplin & Drysdale's Washington, D.C. office, joining the firm in 2004. His practice focuses on the international tax issues of wealthy individuals, including pre-immigration and expatriation planning, structuring cross-border investments, international deferred compensation and retirement planning, and estate planning, including the use of domestic and foreign trusts. He also handles tax controversy matters, including voluntary disclosure proceedings.
Prior to joining Caplin & Drysdale, Mr. Pfeifer was an international tax partner in the National Tax Department of Ernst & Young LLP, where he directed that firm’s international private client practice. From 1993-1995, Mr. Pfeifer was the Special Assistant to the Associate Chief Counsel (International) at the Internal Revenue Service, where he directed the legislative project that culminated in the 1996 foreign trust tax changes. While at the IRS, Mr. Pfeifer was also involved with the Clinton Administration’s expatriation tax proposal, the revisions to the section 1441 withholding tax rules, and the development of the “check-the-box” rules for entity classification. Prior to the IRS, Mr. Pfeifer was a tax partner with the London office of Morgan, Lewis & Bockius LLP, where he concentrated on the international tax issues faced by high net wealth individuals, including authors and entertainers.
Mr. Pfeifer is a 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, IBC USA, and the International Fiscal Association. He has also been a guest lecturer at the Georgetown University Law Center and participated on panels sponsored by the American Bar Association and the New York State Bar Association. Mr. Pfeifer has published articles on a variety of international tax issues in TAX NOTES INTERNATIONAL, TAX MANAGEMENT INTERNATIONAL JOURNAL and other tax periodicals.