Michael Karlin

Michael Karlin is a lawyer with over 40 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. Michael’s practice often overlaps with Jane’s and they, as well as three younger partners, work closely together on many matters.

Private client work was always a part of Michael’s practice and it became a significant focus after he started his own firm.  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.  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 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 and Major Tax Planning. 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.

Michael was educated at St. Paul's School, London as well as schools in Israel, New York, Lisbon and Paris. He is a graduate of Trinity College, Cambridge University (B.A. (Hons.), History and Law, 1973; M.A., 1977).

Michael has been married since 1973 to Fiona Karlin.  They have two children, born in 1983 and 1985.  He has been active for many years as a youth soccer coach, referee and instructor in American Youth Soccer Organization Region 76 (Beverly Hills) and in other nonprofit organizations, including Invertigo Dance Theatre, of which he is the Treasurer. He is also the webmaster for websites of AYSO Region 76, AYSO Area 1-P and the Docent Council of the Los Angeles County Museum of Art.

Michael is fluent in French and conversant in several other European languages.  For several years, he has been learning Japanese – compared to which he considers international tax to be trivially easy.

Recent Speaking Engagements:

  • “Taxation of, and Withholding on, Transfers of Partnership Interests Under the Section 864(c)(8) and 1446(f) Regulations,” Panelist, American Bar Association Section of Taxation Winter Meeting, January 29, 2021.

  • “Tax Residence and Nexus in the Time of the Plague,” Moderator, American Bar Association Section of Taxation Fall Meeting, October 2, 2020.

  • “United States Tax Residency: COVID-19 and Beyond”, Panelists, STEP Los Angeles, June 24, 2020.

  • "Outbound Planning and Choice of Entity Considerations for Individuals," Panelist, 78th New York University Conference on Advanced International Taxation, July 19, 2019.

 

Publications:


View Michael Karlin's Publications