Michael Karlin

Practice Areas

Michael advises individuals and families from abroad who invest in or move to the United States as well as U.S. individuals and families who invest and move abroad, including the ever-increasing regulatory and reporting obligations associated with such activities. Pre-immigration and expatriation planning are an important part of his practice. He also advises individuals and closely held businesses on the tax and business aspects of operating outside their home jurisdiction.

Career

Michael Karlin is a lawyer with nearly 50 years of experience advising corporate and individual clients on tax, estate planning and business matters involving a cross-border element. Michael began his career in London in 1975 as an articled clerk and assistant solicitor at the firm of D.J. Freeman & Co. (now part of Locke Lord LLP). He was admitted as a solicitor in 1977. In 1980, he became a member of the California Bar and he has resided in California ever since. After three years with Gelles, Singer & Johnson, a boutique private client firm in Los Angeles, he became an associate and then a partner of Morgan, Lewis & Bockius. He then spent three years (1997-2000) as a principal in the international tax services group of KPMG, before starting his own firm in 2001. That firm is now part of Karlin & Peebles, LLP, co-founded in 2007 by Michael together with Jane Peebles, a well-known domestic and international estate planner and expert on cross-border philanthropy.

Professional Memberships

Solicitor, England and Wales (admitted 1977)

California State Bar (admitted 1980)

Fellow, American College of Tax Counsel (since 2020)

Member, American Bar Association (1985 to date)

Member, Society of Trust and Estate Practitioners (2007 to date)

Board Member, Invertigo Dance Theatre (2012-2021)

Webmaster, Docent Council, Los Angeles County Museum of Art (2004-2024)

Youth Soccer Coach, Referee and Instructor, Board Member, founding Webmaster, American Youth Soccer Organization Region 76 (since 1981)

Publications

“Rethinking the Path to Corporate Transparency,” Tax Notes International (Volume 114, April 1, 2024)

“Structuring Foreign Investment in U.S. Real Estate,” NYU Institute on Federal Taxation (February 2024)

“The Moores — Nobody Expects the Spanish Inquisition,” Tax Notes International (October 2023)

"Pisoned Gifts: The Case for Reform of Section 6039F," Tax Notes International (March 2023)

“Treaty Nonresidents: The Umpire Strikes Back,” Tax Notes International (March 2023)

“International Estate Planning”, Journal of International Taxation (September 2022)

Experience

Private client work was always a part of Michael’s practice and it became a significant focus after he started his own firm. He has helped to establish corporations, companies, partnerships and joint ventures in many parts of the world and worked extensively on foreign and domestic trusts. In recent years, he has helped many taxpayers deal with the tax and reporting consequences of foreign financial accounts and holdings, including through offshore voluntary disclosures, streamlined disclosures, and other ways of handling non-compliance.

Michael has been an active member of various professional organizations, including the American Bar Association, the Society of Trust and Estate Practitioners, the USC Institute on Federal Taxation, the State Bar of California, the New York University School of Professional Studies, and the Los Angeles County Bar Association. He was elected in 2020 as a fellow of the American College of Tax Counsel. He has spoken on many occasions to those and other groups and he also is a prolific contributor of articles to professional publications, which have included the Tax Notes, the Tax Lawyer, the Journal of International Taxation, Tax Management International Journal, the Practicing Law Institute, and Major Tax Planning (USC). Over the years, he has submitted or participated in the submission of many comments on tax legislation, regulations and tax reform and in 2020 started and led a national group that obtained relief from the IRS on the application of U.S. tax residence rules for non-citizens stranded in the United States because of the COVID-19 pandemic. He is currently working actively on efforts to improve IRS administration of penalties relating to foreign gifts and trusts.

Awards