Michael Karlin

Michael Karlin is a California attorney and an English solicitor with over 35 years of experience advising clients on the taxation of cross-border transactions and investments. Michael has particular experience in structuring international businesses and finance transactions, advising on cross-border taxation, tax treaties, withholding taxes, moving to and from the United States and planning international trusts and estates. He began his career as a solicitor at DJ Freeman (later known as Kendall Freeman and now part of Locke Lord) in London. He became a member of the California Bar in 1980 and was a partner for many years at a leading U.S. firm, Morgan, Lewis & Bockius LLP, resident in the Los Angeles office. He also spent three years as an international tax partner of KPMG LLP.

Publications:

• Landing Safely in Area 51 – Counseling Aliens About U.S. Taxes -Presentation to the Orange County Estate Planning Council on November 13, 2012
• Planning for Foreign Individuals with U.S. Activities: Where Tax and Immigration Law Meet (and Sometimes Collide) - Presentation to 2012 Annual Meeting of the California Tax Bar and Tax Policy Conference, November 1, 2012 (co-presenter with Linda Dodd-Major)
• Fundamentals of United States Taxation of Foreign Trusts, Grantors and Beneficiaries - Presentation to The 1st Annual STEP Wyoming Conference, September 2012 (co-presented with G. Warren Whitaker)
• Now You See Them: U.S. Reporting Requirements for Tax Treaty Nonresidents - Tax Notes International, July 16, 2012
• Tax Structuring of Foreign Investment in U.S. Real Estate With a N.Y. Twist -Proceedings of the New York University 70th Institute on Federal Taxation, May 2012 (co-author with Alan Appel, John Barrie and Michael Hirschfeld)
• Foreign Investment in U.S. Real Estate - Presentation to New York University 70th Institute on Federal Taxation, November 2011 (in collaboration with Michael Hirschfeld)
• Fundamentals of United States Taxation of Foreign Trusts, Grantors and Beneficiaries - Presentation to STEP Pacific Rim Conference, May 2011 (co-presenter with M. Katharine Davidson and Kent D. Lawson)
• The Meaning of Residence for FBAR Purposes - Journal of Tax Practice & Procedure”, February-March 2011 (the version on this site was updated in May 2011 from the one published by the Journal to fully take into account the final FinCEN regulations on FBARs...
• Planning for Mobile Executives and Business Owners Relocating to the U.S.- Presentation to the ABA Section of Taxation, Boca Raton, January 2011 (co-presenter with Gary Lusk, KPMG LLP, and Grace Fleeman, Office of IRS Chief Counsel (International))
• Is It Safe? Dealing with the International Aspects of the United States Tax System - Presentation to UBS Securities on June 8, 2010
• International Estate Planning - Major Tax Planning (Proceedings of the 61st Annual Institute on Federal Taxation of the USC Law School), published summer 2009 (co-author with Jane Peebles)
• Living with the Final Partnership Withholding Regulations - Tax Management Memorandum, February 2009 (co-author)
• Expatriate Games – New Sections 877A and 2801 - Presentation to ABA Tax Section Meeting, January 2009. The outline deals with the new tax regime, effective June 17, 2008, relating to U.S. citizens and long-term green card holders who become “covered expatriates”.
• Strangers in Paradise – and what to do about them - Presentation to UBS Securities, September 2008
• Home Thoughts From Abroad – Foreign Purchases of US Homes - Tax Notes, September 2007 (co-author).  More detailed discussion of the issues considered in “Home Sweet Home Away From Home”
• Home Sweet Home Away From Home - Outline for ABA Section of Taxation panel presentation, October 2006.  The outline deals with the tax considerations that apply to the purchase by a foreign person of a home in the United States.
• Kissing the Blarney Stone – A Practical Guide to Structuring Partnership Agreements and Limited Liability Company Operating Agreements in Light of the Section 1446 Regulations - Tax Management Memorandum, May 2006 (co-author)
• Uncle Sam Meets Uncle Scrooge – The Temporary Regulations on Foreign Partner Withholding - Journal of International Taxation, December 2005, part 2 of two-part article (co-author)
• At Long Last . . . The IRS Issues Final Regulations on Foreign Partner Withholding - Journal of International Taxation, October 2005, part 1 of two-part article  (co-author)
• American Bar Association Section of Taxation, “Comments on Proposed and Temporary Regulations under Section 1446” - October 2005 (co-author and principal editor). These comments dealt with proposed and temporary regulations under section 1446 issued in May 2005 as well as a couple of issues under the final regulations issue at the same...
• American Bar Association Section of Taxation, “Comments on Proposed Regulations under Section 1446” - January 2004 (Section 1446 deals with withholding on foreign partners in partnerships engaged in a U.S. trade or business – Michael served as co-editor and principal author of the comments); a version of this was also...
• U.S. Estate Planning for Nonresident Aliens Who Own Partnership Interests- Tax Notes, 2003 (editor and co-author)
• Coming to America – When Does Tax Residence Begin? - Journal of International Taxation, 2002
• Virtual Withholding: Expanding the Observable Universe - Journal of International Taxation, 1999
• On-Line, Off-Base: The Computer Program Final Regulations Miss an Opportunity - Journal of International Taxation, 1999 (co-author)
• Using the Portfolio Interest Exemption - U.S. Taxation of International Operations, Warren Gorham & Lamont, 1988-1999 (looseleaf)
• Introduction to The Portfolio Interest Exemption - U.S. Taxation of International Operations, Warren Gorham & Lamont, 1988-1999 (looseleaf)
• Pocket Switching – The Taxation of Electronic Commerce - Major Tax Planning (Proceedings of the 50thAnnual Institute on Federal Taxation of the USC Law School), 1998
• Foreign Trusts and Gifts: It’s Getting Warm Offshore - Journal of International Taxation, 1997 (two parts) (editor and co-author)
• Computer Program Prop. Regs. Are a Good But Cautious Start - Journal of International Taxation, 1997
• Other Publications by Michael Karlin - “To Protect and Swerve – Asset Protection and the OJ Case”, California Law Business, 1996 “IRS proposes comprehensive revision of rules on withholding of payments to foreigners”, The In-House Lawyer(London), 1996 “Tax Planning for Doing Business in Mexico”,...
• Offshore Compliance Update – The (Swiss) Clock Is Ticking - Presentation to STEP Los Angeles, July 10, 2014 (with Scott Michel of Caplin & Drysdale and Matthieu Balmer, RBC Geneva).  Additional materials available on request.
• Outward Bound – Structuring Considerations for Closely Held Businesses Expanding Abroad - Presentation to STEP Los Angeles Mini-conference, November 2014
• Foreign Investment in U.S. Real Estate - Presentation to the Los Angeles County Bar Association Crocker Symposium, November 2014
• Request for Guidance Regarding Dual Residents under Treasury Regulations Section 301.7701(b)-7 Who Are Treated as Nonresident Aliens of the United States - Paper presented on behalf of The State Bar of California Taxation Section to Congress and the Administration, May 2015 (co-author with Liliana Menzie of DLA Piper, LLP) – This paper will be available on this website...
• Foreign Financial Assets: You Can Run, But You Cannot Hide -Presentation to USC Gould School of Law 2015 Tax Institute, January 2015 (co-presenter with Edward M. Robbins, Jr., Hochman Salkin Rettig Toscher & Perez, PC, Beverly Hills and Andy Mattson, Moss Adams, LLP, Silicon Valley)