Charles Plambeck rejoined Caplin & Drysdale as Of Counsel in the International Tax Group in 2025 after a career of almost three decades in cross-border structured finance. For the last 24 years, was a Managing Director at Citigroup, and before that at Deutsche Bank and Bankers Trust. Mr. Plambeck draws on that experience and his expansive knowledge of international tax—particularly its intersections with banking regulation, accounting, credit markets and other fields—to assist the firm’s clients.

Services

Mr. Plambeck advises leading financial institutions and multinational corporations on a broad range of complex international tax issues. He represents clients on transactions, planning, audits and appeals, advance pricing agreements (APAs), and mutual agreement procedures (MAPs).

Highlights

At Citigroup, Mr. Plambeck was the head of Structured Bank Finance, a global team transacting as principal in a wide range of cross-border and domestic transactions. Since 2023, Mr. Plambeck has taught international taxation as an Adjunct Professor of Law at UNC School of Law.

Mr. Plambeck served as the Special Counsel in the Office of Chief Counsel of the IRS within the U.S. Treasury Department. During his tenure, he was a primary author of regulations under IRC Section 988, governing foreign currency transactions. Mr. Plambeck also authored regulations dealing with cross-border derivatives transactions, U.S. branch operations of foreign banks, foreign tax credit calculations, and other guidance relating to international finance.

Mr. Plambeck was a Partner at Caplin & Drysdale in Washington from 1992 to 1997. 

Admissions & Education

Bar & Court Admissions
  • District of Columbia
Education

J.D., University of North Carolina School of Law, 1986

A.B., University of North Carolina at Chapel Hill, 1983 

Recognitions & Noteworthy

Honors & Recognitions

UNC Law Alumni Association Extraordinary Service Award, 2022

Government Service

Special Counsel to the Office of Chief Counsel of the Internal Revenue Service, U.S. Treasury Department, 1988-1992

Professional Activities & Affiliations

Professional Activities
  • Adjunct Professor of Law, University of North Carolina
  • President, UNC Law Foundation

Newsroom & Publications

Publications & Alerts
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