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Covington & Burling LLP

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Michael Caballero

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Covington & Burling LLP

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Michael Caballero is a partner in the Washington office and a member of the Tax Practice Group. His practice focuses on international tax matters, including structural and transactional tax planning, as well as tax controversy and other tax policy work.


Mr. Caballero recently served as the International Tax Counsel in the U.S. Department of the Treasury’s Office of Tax Policy. While at the Treasury, he participated in the development of legislation, regulations and administrative guidance concerning international tax matters; oversaw the U.S. income 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). He also was previously a member of the Office of International Tax Counsel for almost six years as an Attorney Advisor and Associate International Tax Counsel. In between his two positions at the Treasury Department’s Office of Tax Policy, Mr. Caballero practiced as a tax partner at two global law firms.


New York University School of Law, LL.M., 2000; Georgetown University Law Center, J.D., 1994 (cum laude; Georgetown Immigration Law Journal, Editor; Sewall Key Prize; RIA Tax Publishing Division Student Award); University of Notre Dame, B.S. in Mathematics, 1991 (magna cum laude).

United States: Tax

International tax

Within: International tax

At Covington & Burling LLP, clients recommend head of tax Daniel Luchsinger in Washington DC and capital markets lawyer Bruce Bennett in New York for delivering ‘excellent service in all areas’. The practice focuses on cross-border tax planning and restructuring, compliance and risk management, as well as controversy matters. The key lawyers-Luchsinger, Robert Culbertson, Samuel Maruca, Michael Caballero, William Chip and Dirk Suringa (all based in Washington DC)-advise clients such as Barclays, Commerzbank, General Electric and United Technologies Corporation.

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US taxes: non-contentious

Within: US taxes: non-contentious

Covington & Burling LLP’s tax practice acts for multinational corporations and private equity funds in tax issues arising from M&A activity, joint ventures, capital markets transactions and internal restructurings. Dan Luchsinger led the US tax advice to Weyerhaeuser REIT on its merger with Plum Creek REIT, which involved the application of of rules concerning REITs and taxable REIT subsidiaries. It also acted for Allergan on the US income tax aspects of the $40bn sale of its generics business to TEVA Pharmaceutical Industries. Sam Maruca, Robert Culbertson, Michael Caballero and Susan Leahy are also recommended.

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