- 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 (2005-2016)
Selected for inclusion in Washington, D.C., Super Lawyers (2008-2015)
Documents by this lawyer on Martindale.com
Congress Amends Section 831(b): Is This the Beginning of the End of Section 831(b) Abuses?
Dennis L. Allen,Thomas A. Gick,Michael R. Miles,Mary E. Monahan,William R. Pauls, December 22, 2015
On December 18, 2015, Congress passed and President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (Act), which made several significant amendments to section 831(b) of the Internal Revenue Code. Prior to these amendments, section 831(b) permitted an insurance company...
Tax Court Holds that Residual Value Insurance Qualifies as Insurance for Tax Purposes
Dennis L. Allen,Thomas A. Gick,Michael R. Miles,Mary E. Monahan,William R. Pauls, September 24, 2015
On September 21, the United States Tax Court held in favor of the taxpayer in R.V.I. Guaranty Co., Ltd. and Subsidiaries v. Commissioner, 145 T.C. No. 9 (2015). The court concluded that the residual value insurance policies issued by RVI1 qualify as insurance policies for U.S. federal income tax...
IRS Extends FATCA Transition Rules
Dennis L. Allen,Robert S. Chase,Thomas A. Gick,Michael R. Miles,Mary E. Monahan, September 23, 2015
On September 18, 2015, the Internal Revenue Service (IRS) issued Notice 2015-66, in which Treasury and the IRS announced that they intend to extend certain transition rules and modify certain other reporting rules under the Foreign Account Tax Compliance Act (FATCA).
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