Michael J Caballero

International tax planning, focusing on GILTI, foreign tax credits, and foreign restructurings, and controversy resolution, including audits and ruling requests, and policy matters involving administrative and legislative solutions.

Served two tenures in Treasury’s Office of Tax Policy, most recently as International Tax Counsel, with responsibility for international tax legislation, regulations and administrative guidance, the U.S. income tax treaty program, and representation of the United States at the OECD. Served as Attorney-Advisor responsible for foreign tax credits, cross-border M&A, inversions, and international partnerships.

B.S. (Mathematics), magna cum laude, University of Notre Dame; J.D., cum laude, Georgetown; LL.M. (Taxation), NYU.