Michael R. Miles: Lawyer with Sutherland Asbill & Brennan LLP

Michael R. Miles

Washington,  DC  U.S.A.

Peer Rating
AV® Preeminent

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Practice Areas

  • Tax
  • Federal Tax
  • Financial Services
  • Insurance Taxation
  • International Tax
  • Insurance M&A and Demutualizations
  • Mergers & Acquisitions
  • Mutual Funds
  • Retirement Products & Services
  • Tax Controversy & Litigation
  • Insurance
Contact InfoTelephone: 202.383.0204
Fax: 202-637-3593
University Ohio University, B.S., with honors Member, Honors College
Law SchoolThe Ohio State University, J.D., with honors Order of the Coif; Georgetown University Law Center, LL.M., with honors
Admitted1978, Ohio; 1983, District of Columbia

Professional Activities
Member, Tax Section, American Bar Association
Member, Tax Section, Federal Bar Association
Member, Tax Section, District of Columbia Bar

BornSalem, 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.

Selected Experience
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

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Required Summer Reading: Guidance Issued on the Tax Treatment of Guaranteed Minimum Benefit Hedges and Identified Mixed Straddles
Dennis L. Allen,Thomas A. Gick,Jerome B. Libin,Jeffrey H. Mace,Michael R. Miles, July 24, 2014
Treasury and the IRS offered two pieces of highly anticipated guidance on July 18 that are particularly relevant to the life insurance industry.

Clock Is Ticking...Relief for Late Filed GRAs Expected to Expire Soon
Robert S. Chase,Michael R. Miles,Jennifer B. Molnar,William R. Pauls,Carol P. Tello, May 27, 2014
Time may be running out for taxpayers to correct technically deficient gain recognition agreements (GRAs) under the relief procedure contained in the Directive on Examination Action With Respect to Certain Gain Recognition Agreements, LMSB-4-0510-017 (July 26, 2010) (the Directive). Historically,...

To the Direct Acquirer Belong the Tax Attributes: Proposed Regulations Modify the Definition of Acquiring Corporation for Purposes of IRC § 381
Dennis L. Allen,Robert S. Chase,Reginald J. Clark,Jeffrey H. Mace,Michael R. Miles, May 13, 2014
On May 7, Treasury and the IRS published proposed regulations addressing which corporation succeeds to the tax attributes of another corporation that transfers assets in an acquisitive asset reorganization described in IRC §§ 368(a) and 381(a)(2) (the Proposed Regulations). In brief, the...

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Office Information

Michael R. Miles

700 Sixth Street NW, Suite 700
WashingtonDC 20001-3980


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