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David S. Miller

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David S. Miller

Partner
 
Cadwalader, Wickersham & Taft LLP
One World Financial Center
New York, New York  10281-0006
(New York Co.)

Telephone: (212) 504-6000
Fax: (212) 504-6666
http://www.cadwalader.com



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Experience & Credentials
 


Practice AreasFederal Income Tax
 
EducationColumbia University, J.D., 1989; New York University, LL.M., 1994, University of Pennsylvania, B.A., summa cum laude, 1986
 
Admitted1991, New York
 
MembershipsNew York State Bar Association (Secretary).
 
BornBethesda, Maryland, April 16, 1965
 
BiographyPhi Beta Kappa. Harlan Fiske Stone Scholar. Notes and Comments Editor, Columbia Law Review, 1988-1989. Author: "Distinguishing Risk: The Disparate Tax Treatment of Insurance and Financial Contracts in a Converging Marketplace," 55 Tax Lawyer 481 (Winter 2002); "An Overview of the U.S. Federal Income Tax Treatment of Collateral Debt Obligation Transactions," 17 Journal of Taxation of Financial Institutions 27 (July/August 2001); "Snake in the Box: The Hazards of Policymaking With `Anti-Abuse' Rules," 88 Tax Notes 107 (October 2, 2000); "Reconciling Policies and Practice in the Taxation of Financial Instruments," 77 Taxes 236 (March, 1999); "An Overview of the Taxation of Credit Derivatives" (Chapter) in The Use of Derivatives in Tax Planning (Frank J. Fabozzi & Robert P. Molay, editors) (1998); "Taxpayers' Ability to Avoid Tax Ownership: Current Law and Future Prospects," 51 The Tax Lawyer 279 (1998); and "The Tax Nothing," 74 Tax Notes 619 (February 3, 1997). Winner: The Burton Award for Legal Achievement (recognizing exceptional legal writing). Listed in Chambers Global's The World's Leading Lawyers and Chambers USA: America's Leading Lawyers.
 
ISLN901677776
 

Documents by this lawyer on Martindale.com


FBAR Filing Requirements for Owners of Foreign Accounts, Hedge Fund Investors, Hedge Fund Managers, and Financial Institutions; June 30, 2009 Filing Deadline Extended until September 23, 2009 for Certain Filers
Raymond Banoun, David S. Miller, Daniel J. Mulcahy, Shlomo M. Boehm, Shelly Goldklang, July 8, 2009
The Bank Secrecy Act of 1970 authorizes the Secretary of the Treasury to establish recordkeeping and filing requirements for United States persons with financial interests in, or signature authority or other authority over, foreign financial accounts.

Interim Guidance on Deferred Compensation Arrangements under Section 457A of the Internal Revenue Code (IRS Notice 2009-8)
David S. Miller, Mark A. Holdsworth, Karen Walny, February 6, 2009
On January 8, 2009, the Internal Revenue Service issued Notice 2009-8, which provides interim guidance on the application of section 457A of the Internal Revenue Code.


 

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