Michael Miles serves on Sutherland's Executive Committee and is also a member of the firm's Tax Practice Group. He concentrates his practice on the taxation of insurance companies, cross-border transactions and corporate restructurings. He also advises on consolidated return issues, the general taxation of corporations and shareholders, and the taxation of regulated investment companies. Michael 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 the firm in 1983, 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. Representative Experience Michael's recent representative experience includes: · Advising on the tax aspects of the restructuring of the U.S. operations of a publicly traded foreign insurance holding company. · Negotiating the settlement of proposed tax deficiencies of $570 million relating to corporate tax-advantaged transactions. · Advising on the tax issues relating to the acquisition of a $4 billion financial services company and related restructurings and financings. · Representing a selling corporation on its dispositions, in multiple transactions, of subsidiaries with an aggregate value in excess of $1 billion. Professional Honors and Awards · Named to The Best Lawyers in America in the area of tax law (2005-2012) · Selected for inclusion in Washington, D.C., Super Lawyers® (2011) Professional and Community Involvement · Member, Tax Section, American Bar Association · Member, Tax Section, Federal Bar Association · Member, Tax Section, District of Columbia Bar Recent Publications and Speaking Engagements · Co-author, "Permanent Subpart F Exemption Proposed, Certain Unresolved Issues Remain," Tax Management International Journal (June 29, 2009) · Co-author, "Increased Audit Activity Planned for U.S. Federal Excise Tax on Insurance Premiums," Tax Notes International, Vol. 54, No. 6 (May 11, 2009) · Co-author, "New Switzerland-U.S. Tax Treaty Likely to Contain Key Enhancements," Tax Notes International, Vol. 54, No. 4 (April 27, 2009) · Presenter, Federal Bar Association Insurance Tax Conference (2011) · Presenter, Canadian Life and Health Insurance Association Tax Officers Annual Meeting (2004-2011) · Speaker, 2008-2010 Sutherland BDC Roundtables · Presenter, Southern Federal Tax Institute Annual Conference (2003) Industries Financial Services News Sutherland Partnership Makes Leadership Changes
May 9, 2011 Nine Sutherland Attorneys Named D.C. Super Lawyers in 2011
May 3, 2011 Sutherland Represents Tyco Electronics in its Acquisition of ADC
July 14, 2010 Sutherland Represents Solar Capital Ltd. in Initial Public Offering
April 28, 2010 Sutherland Represents Allied Capital Corporation in Merger with Ares Capital Corporation
April 26, 2010 Sutherland Represented Patriot Capital Funding in Merger with Prospect Capital
December 7, 2009 Sutherland Represents Tyco Electronics Ltd. in $675 Million Sale of Its Wireless Systems Business to Harris Corporation
April 28, 2009 Legal Alerts Legal Alert: IRS Issues Interim Guidance on the Federal Income Tax Treatment of Annuity and Life Insurance Contracts with a Long-Term Care Insurance Feature
August 16, 2011 Legal Alert: "SRLY? You Can't Be Serious." "I Am Serious...and Don't Call Me SRLY." The IRS Issues Helpful Guidance on the Application of the SRLY Register Rules to Dual Consolidated Losses
August 11, 2011 Legal Alert: It's Just a Phase: The "Phased Implementation" of FATCA Under Notice 2011-53
July 18, 2011 Legal Alert: IRS Modifies Guidance on Partial Exchanges of Annuity Contracts
June 30, 2011 Legal Alert: The Secret Is Out! Proposed Treasury Regulations Shed New Light on the Controlled Group Deferred Loss "Supersecret Rule," Including Its Application to CFCs
April 25, 2011 Legal Alert: Spring Is in the Air, and So Is FATCA! Notice 2011-34 Offers Another Dose of Much-Anticipated Guidance
April 12, 2011 Legal Alert: Many Happy (Consolidated) Returns or 'Til "DIT" Do Us Part? Final Treasury Regulations Address Intercompany Items of Gain on Member Stock
March 4, 2011 Legal Alert: Ready... Aim...Fire! FY 2012 Budget Proposals (Once Again) Target Insurance Companies
February 16, 2011 Legal Alert: Revision of RIC Tax Rules
December 23, 2010 Legal Alert: FATCA Proposed Legislation Enacted as Part of HIRE Act
March 18, 2010 Legal Alert: FY 2011 Budget Contains a Number of Tax Proposals Targeting Insurance Companies
February 2, 2010 Legal Alert: IRS Announces It Will Require the Disclosure of Uncertain Tax Positions
January 26, 2010 Legal Alert: IRS Rules That Quota Share Reinsurance Arrangements Are "Insurance" and Continues to Apply Prior Principles
December 18, 2009 Legal Alert: IRS Issues Initial Rulings on "Contingent" Annuities
December 7, 2009 Legal Alert: Worker, Homeownership, and Business Assistance Act of 2009 Adds Five-Year Carryback Period for 2008 or 2009 Operations Losses of Life Insurance Companies
November 6, 2009 Legal Alert: Deferred Compensation Timing Rules, Rather Than Subchapter L, Govern Insurance Company's Deduction for Retiree Medical Benefits
October 28, 2009 Legal Alert: IRS Approves "Longevity" Annuity
September 28, 2009 Legal Alert: IRS Concludes That U.S. Lending Activities Conducted Through a Dependent or Independent "Agent" Constitute a U.S. Trade or Business
September 24, 2009 Legal Alert: Proposed Neal Bill Reintroduced to Limit Deductibility of Offshore Related Insurance Premiums
August 3, 2009 Legal Alert: Health Bill Resurrects Treaty Limitation Provision That Attempts To Target Only Haven Controlled Foreign Groups But Misses The Mark
July 21, 2009 Legal Alert: FBAR Filing Requirement for Non-U.S. Persons Temporarily Suspended
June 8, 2009 Legal Alert: FBAR 2008 Revised Instructions Broaden the Class of Filers
June 3, 2009 Legal Alert: IRS Provides Guidance on PPA Rules for Employer-Owned Life Insurance
June 2, 2009 Legal Alert: IRS Rules on Long-Term Care Coverage Provided Through an Annuity Contract
May 12, 2009 Legal Alert: IRS Rules on Secondary Market Sales of Life Insurance Contracts
May 5, 2009 Legal Alert: Permanent Subpart F Rules Proposed for Insurance Companies
April 21, 2009 Legal Alert: Increased Audit Activity for U.S. Federal Excise Tax on Insurance Premium
April 6, 2009 Legal Alert: Swiss Announce Negotiations for a New Tax Treaty With the United States
March 24, 2009 Legal Alert: Proposed Legislation Would Sweep Certain Offshore Corporations Into the U.S. Tax Net and Subject Their Worldwide Income to U.S. Tax
March 9, 2009 Legal Alert: Treasury Money Market Guarantee Program: New Developments for Insurance-Dedicated Funds
October 8, 2008 Legal Alert: Treasury Department Money-Market Mutual Fund Guaranty Program May Present Tax Issues for Insurance-Dedicated Funds
September 24, 2008 Legal Alert: IRS and Treasury Issue 2008-2009 Business Plan
September 17, 2008 Legal Alert: IRS Applies IRC Section 72(w) to Annuity Partially Accrued While a Non-Resident Alien
August 12, 2008 Legal Alert: IRS Clarifies Grandfathering Rules for Split Dollar Life Insurance Contracts
April 2, 2008 Legal Alert: DOL Proposes Small Plan Safe Harbor for Remitting Participant Contributions to Plan
March 3, 2008 Legal Alert: IRS Rules Against Qualified Long-Term Care Insurance in 401(k) Plan
February 21, 2008 Legal Alert: IRS Issues Form to Report Employer-Owned Life Insurance
February 7, 2008 Legal Alert: IRS Issues Ruling and Proposed Guidance Regarding Protected Cell Companies
January 24, 2008 Legal Alert: IRS Implements Information Reporting for Employer-Owned Life Insurance
November 19, 2007 Legal Alert: Liberalization of Variable Insurance Product Diversification Requirements Proposed
July 31, 2007 Publications Permanent Subpart F Exemption Proposed, Certain Unresolved Issues Remain
June 29, 2009 Reprinted with permission Tax Management International Journal, Bureau of National Affairs (BNA) Tax Management Increased Audit Activity Planned for U.S. Federal Excise Tax on Insurance Premiums
May 11, 2009 Reprinted with permission Tax Notes International, Vol. 54, No. 6 New Switzerland-U.S. Tax Treaty Likely to Contain Key Enhancements
April 27, 2009 Reprinted with permission Tax Notes International Vol. 54, No. 4 Events 2010 BDC Roundtable
September 13-14, 2010 Canadian Life and Health Insurance Association Tax Officers Annual Meeting
2004-2010 Southern Federal Tax Institute Annual Conference
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