- Federal Tax
- Financial Services
- Insurance Taxation
- International Tax
- Mergers & Acquisitions
- Mutual Funds
- Retirement Products & Services
- Tax Controversy & Litigation
- Insurance M&A and Demutualizations
- Business Development Companies
|Contact Info||Telephone: 202.383.0204|
|University ||Ohio University, B.S., with honors Member, Honors College|
|Law School||The Ohio State University, J.D., with honors Order of the Coif; Georgetown University Law Center, LL.M., with honors|
|Admitted||1978, Ohio; 1983, District of Columbia|
Member, Tax Section, American Bar Association
Member, Tax Section, Federal Bar Association
Member, Tax Section, District of Columbia Bar
|Born||Salem, Ohio, December 11, 1950|
Michael Miles provides insurance companies with creative solutions and tax planning strategies for their corporate, insurance, and reinsurance transactions, including cross-border transactions, and corporate restructurings. Michael also advises on consolidated return issues, the general taxation of corporations and shareholders, the taxation of regulated investment companies, and the application of withholding rules (including FATCA). He has substantial experience in advising clients on the tax consequences of proposed mergers and other reorganizations, reinsurance transactions, stock and asset acquisitions, and dispositions, distributions, and redemptions.
Before joining Sutherland, Michael served as an attorney in the Office of the Chief Counsel of the Internal Revenue Service (IRS). He has more than 30 years of experience in handling federal tax controversies, first for the IRS and now for the firm's corporate and individual clients, as well as substantial experience in obtaining rulings for clients on corporate tax and other matters and in practicing before the IRS.
Sutherland advises insurance companies in financial services sales.
Sutherland represents Manulife in restructuring U.S. operations.
Sutherland advises on the tax issues in the acquisition of a top financial services company.
Awards and Rankings
Named to The Best Lawyers in America in the area of tax law (2005-2015)
Selected for inclusion in Washington, D.C., Super Lawyers (2008-2014)
Documents by this lawyer on Martindale.com
First Investor Control Case Since 1984 Is Released
Dennis L. Allen,Thomas A. Gick,Jeffrey H. Mace,Michael R. Miles,William R. Pauls, July 7, 2015
On June 30, the Tax Court released Webber v. Commissioner, 144 T.C. No.17, in which the court upheld and applied the principles set forth in the Internal Revenue Service’s (IRS) “investor control” rulings, concluding that for federal tax purposes, the taxpayer in question was the...
Validus Affirmed for All the Right Reasons - The FET Does Not Apply to Wholly Foreign Reinsurance Transactions
Dennis L. Allen,Thomas A. Gick,Jeffrey H. Mace,Michael R. Miles,Mary E. Monahan, June 1, 2015
On May 26, the U.S. Court of Appeals for the District of Columbia affirmed the result of the U.S. District Court for the District of Columbia in Validus Reinsurance, Ltd. v. U.S., 19 F. Supp. 3d 225 (2014), which was the first case to involve a challenge to the Internal Revenue Service’s...
IRS Releases Favorable Private Letter Ruling on “Taxable Annuity.”
Dennis L. Allen,Thomas A. Gick,Jeffrey H. Mace,Michael R. Miles,William R. Pauls, April 16, 2015
On April 10, the Internal Revenue Service (IRS) released PLR 201515001 (Oct. 10, 2014), favorably addressing a “taxable annuity” - essentially, a deferred annuity contract supported, in part, by subaccounts, each of which invested solely in a single publicly available mutual fund. Not...
View Ratings & Reviews
|Profile Visibility |
|#733 in weekly profile views out of 57,729 lawyers in Washington, District of Columbia|
|#32,296 in weekly profile views out of 1,722,821 total lawyers Overall|