FacultyFaculty/Author Profile
Michael H. Plowgian

Michael H. Plowgian


Washington, DC, USA


Michael is a principal in KPMG’s Washington National Tax Office for International Tax.

Professional and Industry Experience

Michael advises multinational corporations regarding international tax planning and policy, with a particular focus on helping clients address the implications of the OECD/G20 BEPS Project, FATCA, and the OECD/G20 Common Reporting Standard.  Michael is a member of the Business Advisory Group that consults with the OECD regarding the Common Reporting Standard and is an active participant in the ongoing consultations on BEPS.

Prior to joining KPMG, Michael was a Senior Advisor on Base Erosion and Profit Shifting (BEPS), at the Organisation for Economic Co-operation and Development (OECD).  In that role, he helped lead the OECD work on BEPS and worked with policymakers from OECD and G20 countries to develop the Action Plan on BEPS. Michael was also involved in the development of the Common Reporting Standard (the “CRS”), a single global standard for automatic exchange of information based on FATCA.

Prior to joining the OECD, Michael was an Attorney Advisor in the Office of the International Tax Counsel at the U.S. Department of the Treasury. While at Treasury, Michael was a principal drafter of the regulatory guidance and intergovernmental agreements under FATCA. He also served as the Co-Chair of the OECD’s Treaty Relief and Compliance Enhancement (TRACE) Project, and was the U.S. representative to Working Party 10 on Exchange of Information and Tax Compliance.

Publications and Professional Engagements

  • Michael is a frequent speaker and moderator at conferences on U.S. international tax issues, including BEPS, FATCA, and the CRS.
  • He is the co-author of the BNA Tax Management Portfolio on U.S. Taxation of Foreign Investment in U.S. Real Estate, and has published several articles on U.S. taxation.

Function and Specialization

Michael H. Plowgian is a principal in KPMG’s Washington  National Tax Office for International Tax. He advises multinational corporations on U.S. international tax aspects of their structures, operations and transactions. He specializes in consulting and advising on issues relating to international tax policy, expense allocation, the source of income rules, foreign tax credits, and subpart F, U.S. taxation of international income.

Professional Associations

  • Member of the District of Columbia Bar Association

Education, Licenses & Certifications

  • Harvard Law School, J.D
  • Tufts University – Fletcher School of Law and Diplomacy, MALD, International Law, International Finance
  • Denison University, B.A. Philosophy, Politics and Economics

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