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- Michael J. Caballero
Michael Caballero is a partner in the Washington office and a vice chair of the Tax Practice Group. His practice focuses on international tax matters, including structural and transactional tax planning, tax controversy, and tax policy work.
Mr. Caballero previously served as International Tax Counsel in the U.S. Treasury Department’s Office of Tax Policy. While at the Treasury Department, he participated in the development of legislation, regulations, and administrative guidance concerning all aspects of international tax matters; oversaw the U.S. tax treaty program; and coordinated the representation of the United States in various international fora, including the Organisation for Economic Co-operation and Development (OECD).
Mr. Caballero previously served in the Office of International Tax Counsel for almost six years as an Attorney Advisor and Associate International Tax Counsel with responsibility for legislative matters and administrative guidance regarding the foreign tax credit, cross-border M&A, inversions, international partnerships, FIRPTA, and PFICs.
Prior to his most recent time at the Treasury Department, Mr. Caballero practiced as a tax partner at two global law firms.
Memberships and Affiliations
- Member of the Advisory Board for the George Washington University-Internal Revenue Service Annual Institute on Current Issues in International Taxation
- Bloomberg BNA U.S. International Advisory Board Member
- Former Chair and Vice-Chair of the D.C. Bar's Taxation Community Steering Committee
- Former Chair and Vice-Chair of the D.C. Bar's Taxation Section's Committee on International Taxation
- D.C. Bar Association, Member
Previous Experience
- International Tax Counsel, Office of Tax Policy, U.S. Department of the Treasury
- Deputy International Tax Counsel, Office of Tax Policy, U.S. Department of the Treasury
- Associate International Tax Counsel, Office of Tax Policy, U.S. Department of the Treasury
- Attorney Advisor, Office of International Tax Counsel, U.S. Department of the Treasury
March 26, 2020, Covington Alert
Late last night, the Senate passed (96-0) the Coronavirus Aid, Relief, and Economic Security ("CARES") Act that was introduced by several Senate Republicans last Thursday. This follows a number of days of whirlwind negotiations, beginning with the Senate where, on Sunday night, a procedural vote failed to garner the 60 votes necessary to move the legislation ...
March 12, 2020, Covington Alert
The Tax Cuts and Jobs Act (“TCJA”) made significant changes to the tax code, a number of which can have unexpected effects when a company loses money in the United States or abroad. While the immediate concerns around the spread of COVID-19 are rightfully focused on public health and welfare, given the current economic fallout arising from COVID-19, companies ...
March 2020
As the legal, regulatory, and commercial implications of coronavirus COVID-19 continue to evolve, our lawyers and advisors are helping clients navigate the complex considerations that companies around the world are facing and develop plans and strategies in response. Reach out to our COVID-19 task force at COVID19@cov.com. Below is a compendium of resources ...
December 9, 2019, Covington Alert
On December 6, 2019, the Office of the U.S. Trade Representative (USTR) published a notice determining that the Digital Service Tax of France (“the DST”) is unreasonable or discriminatory and burdens or restricts U.S. commerce under Section 301 of the Trade Act of 1974.
December 5, 2019, Covington Alert
On December 2, 2019, the U.S. Department of the Treasury ("Treasury Department") and the Internal Revenue Service ("IRS") released final regulations, as well as new proposed regulations (the “2019 proposed regulations”), addressing issues related to the determination of foreign tax credits in light of the changes made by the Tax Cuts and Jobs Act (“TCJA”).
Comments on Section 59A Proposed Regulations (Internal Revenue Service REG–104259–18) – Treatment of a Loss Recognized upon the Transfer of Property
February 19, 2019, Covington Comment Letter
Comments on Section 59A Proposed Regulations (Internal Revenue Service REG–104259–18) – Applicability of BEAT to Global Services Provided by U.S. Equipment Manufacturers
February 19, 2019, Covington Comment Letter
Comments on Section 59A Proposed Regulations (Internal Revenue Service REG–104259–18) – Proposals Regarding TLAC Securities, Securities Lending Transactions, and Internal Dealings
February 19, 2019, Covington Comment Letter
January 9, 2019, Covington Alert
On January 2 of this year, former House Ways & Means Chairman Kevin Brady (R-TX) introduced the Tax Technical and Clerical Corrections Act. It contains technical corrections to existing tax law, many of which relate to Public Law 115–97, also known as the Tax Cuts and Jobs Act (TCJA) of 2017. Mr. Brady introduced this measure as a discussion draft and has ...
Comments on Section 965 Proposed Regulations (Internal Revenue Service REG-104226-18) - Downward Attribution Under Section 318 in Examples 1 & 2 of Proposed Treasury Regulation Section i.965-i(g)
September 24, 2018, Covington Comment Letter
Treatment of Section 78 Gross-Up Amounts Relating to Section 960(b) Foreign Income Taxes
July 22, 2018, Covington White Paper
BEAT Implementation Proposals Related to Global Services Operations
July 18, 2018, Covington White Paper
Request for Guidance in Applying Controlled Foreign Corporation Rules following P.L. 115-97 (Repeal of Section 958(b)(4))
March 19, 2018, Covington Comment Letter to The Honorable David Kautter and The Honorable William Paul
Taxpayers Should Prepare Now for GILTI and FDII
February 5, 2018, Tax Notes
Michael Caballero spoke at a District of Columbia Bar Taxation Community event and is quoted in a Tax Notes article examining why taxpayers should evaluate their current structures to minimize their potential tax burdens from global intangible low-taxed income (GILTI) and foreign-derived intangible income (FDII). According to Caballero, an issue affecting ...
Clarifications On Tax Reform Will Come, Officials Say
January 25, 2018, Law360
Michael Caballero spoke at a tax conference in Washington and is quoted in a Law360 article regarding the recently enacted U.S. tax legislation. According to Caballero, the tax law’s creation of reasonably low-tax foreign income that’s now returned means that “we’ve got partially exempt and partially taxed income that we now have to take and push through the ...
November 13, 2017, Tax Analysts
Michael Caballero is quoted in a Tax Analysts article regarding how the tax reform bill further complicates the foreign tax credit (FTC). The current FTC rules are "insanely complex," says Caballero. "The one thing that's not in this bill, at least on the international side, is an ounce of simplification."
April 27, 2017, Global Policy Watch
On April 26, 2017, Treasury Secretary Steven Mnuchin and National Economic Council Director Gary Cohn introduced the Trump Administration’s tax reform proposal (the “Trump Proposal”) in a briefing. The proposal appears to borrow heavily from the tax reform plan put out by Mr. Trump during his presidential campaign with the significant exception that this ...
April 27, 2017, Covington Alert
On April 26, 2017, U.S. Treasury Secretary Steven Mnuchin and National Economic Council Director Gary Cohn introduced the Trump Administration’s tax reform proposal (the “Trump Proposal”) in a briefing. The proposal appears to borrow heavily from the tax reform plan put out by Mr. Trump during his presidential campaign with the significant exception that this ...
October 8, 2014, Global Policy Watch
On Monday, September 22nd, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) published Notice 2014-52 (the “Notice”) announcing their intention to issue regulations that would address corporate inversion transactions. If issued in the form described in the Notice, the regulations would prevent certain narrow categories of inversions, ...
January/February 2014, 66 The Tax Executive 21
August 30, 2012
WASHINGTON, DC, August 30, 2012 — Michael Caballero, the former international tax counsel at the U.S. Treasury Department, will be joining Covington & Burling and its tax practice. Mr. Caballero will be based in the firm’s Washington office as a partner effective September 10. At the Treasury Department, Mr. Caballero served as one of the administration’s most ...
2010, BNA Tax Management Portfolio
1996, Tolley’s International Tax Planning
Winter 1995, 48 Tax Lawyer 435
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- Best Lawyers in America
- Legal 500 US
- Washingtonian, "Top Lawyers"
- Expert Guides, Best of the Best USA
COVID-19: Legal and Business Toolkit
We are helping clients around the world navigate this evolving, complex situation.