Michael G. Pfeifer
Day Pitney LLP
555 11th Street NW
Washington, DC 20004
U.S.A.
Phone: (202) 218-3902
Fax: (202) 354 5329
Email: mpfeifer@daypitney.com
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 - 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 - Listed in the 2010-2014 editions of The Best Lawyers in America in the category of Trusts and Estates
- Ranked as a Top Lawyer in Tax in the 2011 and 2013 editions of Chambers USA: Wealth Management: Eastern Region (Nationwide)
- Listed in the 2010-2013 editions of Super Lawyers
- 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
- AV rated by Martindale-Hubbell
Recent Publications
Mr. Pfeifer writes frequently on international tax matters. He is also mentioned in major media outlets.
- The Current State of Expatriation, in A Guide to International Estate Planning, American Bar Association, 2nd Ed. (2013)
- FATCA: An Overview of Its Scope and Application to Non-U.S. Entities Chapter, in The International Comparative Legal Guide to: Private Client 2014 Edition (December 23, 2013)
- FATCA Reporting - Are Trusts and Trustees Caught in the Net?, Financier Worldwide (July 2013)
- 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, D.C. (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)
Practice Areas - Private Client
- International Tax
- Tax Controversies
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
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