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Michael R. Miles

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Michael R. Miles

Partner
 
Sutherland Asbill & Brennan LLP
1275 Pennsylvania Avenue, NW
Washington, District of Columbia  20004-2415


Telephone: 202-383-0100
Fax: 202-637-3593
http://www.sutherland.com



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Practice AreasCorporate Taxation; Corporate Tax Planning; Federal Income Tax; Federal Tax Controversies; Leasing
 
EducationOhio State University, J.D., 1978; Georgetown University Law Center, LL.M., 1983, Ohio University, B.S., honor college, 1972
 
Admitted1978, Ohio; 1983, District of Columbia
 
MembershipsThe District of Columbia Bar (Member, Taxation Section); Federal (Member, Taxation Section) and American (Member, Taxation Section) Bar Associations.
 
BornSalem, Ohio, December 11, 1950
 
BiographyOrder of the Coif. Attorney, Internal Revenue Service, Office of Chief Counsel, 1978-1982.
 
ISLN904805718
 

Documents by this lawyer on Martindale.com


IRS Concludes That U.S. Lending Activities Conducted Through a Dependent or Independent "Agent" Constitute a U.S. Trade or Business
Michael R. Miles, Carol P. Tello, Christopher Ocasal, October 1, 2009
On September 22, 2009, in its first written guidance on the topic, the IRS Chief Counsel's Office issued a memorandum to the IRS's Manhattan Financial Services Office in which the Associate Chief Counsel (International) concluded that interest income from loans made by a foreign lender to a U.S....

Permanent Subpart F Rules Proposed for Insurance Companies
Michael R. Miles, Carol P. Tello, Christopher Ocasal, May 22, 2009
On April 2, 2009, Congressmen Richard Neal (D-Mass) and Pat Tiberi (R-Ohio) introduced H.R. 1944, which would permanently extend the Subpart F exemption for "active financing income."


 

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