Michael J. Miller has provided U.S. tax advice to domestic and international clients for more than 20 years. Working with foreign clients, he has structured inbound U.S. investments and operations to avoid the creation of a U.S. permanent establishment and developed structures designed to take advantage of U.S. income tax treaties, the withholding tax exemption for portfolio interest, and other special rules for minimizing U.S. tax. This includes consideration of various anti-abuse rules, such as earnings-stripping limitations and restrictions on the ability to engage in treaty shopping or earn income through hybrid entities. He has worked with U.S. multinationals to structure their foreign investments and operations so as to minimize the impact of certain restrictions on outbound transfers and anti-deferral rules applicable to shareholders of controlled foreign corporations and passive foreign investment companies, as well as maximize the utilization of foreign tax credits.

Michael is an editor of the International column for the Journal of Taxation, and a member of the Advisory Boards of the International Tax Journal and the BNA Tax Management International Journal. He has co-authored two BNA Portfolios: Income Tax Treaties - The Limitation on Benefits Article and U.S. Taxation of International Shipping and Air Transport Activities.

Michael is a former Chair of the U.S. Activities of Foreign Taxpayers Committee of the American Bar Association Tax Section and the Business Entities Committee of the New York City Bar. Michael is designated as a leading tax professional in Chambers USA, Super Lawyers, and Legal Media Group's Expert Guides: Tax Advisors.

He received a B.A. cum laude from Columbia College and his J.D. from New York University. He clerked on the U.S. Tax Court for the Honorable James S. Halpern from 1991-1993. Direct Tel. (212) 903-8757.

Foreign Corporation Not Taxable on Redemption of Partnership Interest: Tax Court Rejects Rev. Rul. 91-32

by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, August 4, 2017
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Reliance on a CPA As Reasonable Cause: "Neanatology" Lives on After "Grecian Magnesite Mining"

by Ellen Seiler Brody, Michael J. Miller
Published: Bloomberg BNA Daily Tax Report, August 3, 2017
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Tax Court Rejects Revenue Ruling 91-32 -- Holds Greek Corporation's Gain from the Redemption of Its Partnership Interest Not To Be Taxable as Effectively Connected Income

by Michael J. Miller, Ellen Seiler Brody, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 24, 2017
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Snowbirds Flying Blind: Beware the US Residence Trap

by Michael J. Miller
Published: Canadian Tax Journal, August 1, 2014
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Options to Consider for Non-US Investors in US Real Estate

by Michael J. Miller
Published: The Canadian Tax Journal, October, 2013
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Expats Live in Fear of Malevolent Time Machine

by Michael J. Miller, Ellen Seiler Brody
Published: International Tax Journal, March 5, 2013
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IRS Provides Detailed Guidance on 2012 Offshore Voluntary Disclosure Program and Announces New Alternative Procedure for Certain Taxpayers Living Abroad

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen, Ellen Seiler Brody
Published: R&H Letter to Clients and Friends, July 3, 2012
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Foreign Asset Reporting Under Code Section 6038D

by Michael J. Miller, Ellen Seiler Brody
Published: International Tax Journal, May-April, 2012
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Shameful Double Taxation of Individual Expatriates

by Michael J. Miller
Published: International Tax Journal, July 01, 2011
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IRS Modifies 2011 Offshore Voluntary Disclosure Initiative to Reduce Penalties for Certain Participants and Permit Extensions

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, June 22, 2011
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IRS Further Extends Deadline for 2009 and Prior FBARs Required to be Filed by U.S. Persons With Signature Authority but No Financial Interest in Foreign Accounts

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, June 21, 2011
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The 2011 OVDI: Is Voluntary Disclosure Really Better the Second Time Around?

by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, May 13, 2011
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Highlights of the New FBAR Regulations and Revised FBAR for 2010 Filings Due June 30, 2011

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, April 06, 2011
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Certain Taxpayers May Avoid Penalties If They File Delinquent Information Returns Relating to Foreign Accounts, Foreign Entities, and Foreign Gifts

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, March 02, 2011
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IRS Announces 2011 Offshore Voluntary Disclosure Initiative With August 31, 2011 Deadline

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, February 09, 2011
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Tax Court Approves Tax-Free Payment of Outbound Guarantee Fees

by Michael J. Miller, Libin S. Zhang
Published: BNA Tax Management - International Journal, August 13, 2010
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2010 FBAR Update

by Michael J. Miller, Libin S. Zhang
Published: International Tax Journal, May 2010
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Foreign Account Tax Compliance Provisions Have Far-Reaching Effect

by Michael J. Miller, Peter H. Blessing
Published: Canadian Tax Foundation - 61st Annual Conference, April 01, 2010
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IRS Issues Relief from FBAR Filing Obligations for Three Groups

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, March 03, 2010
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Reflections on the Application of Income Tax Treaties to Hybrid Entities That Earn Non-FDAP Income

by Michael J. Miller, Libin S. Zhang
Published: International Tax Journal, January 01, 2010
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IRS Extends Deadline For Voluntary Disclosure Program

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, September 24, 2009
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Taxpayers Still Have Time to Resolve Offshore Tax Issues Through the Voluntary Disclosure Program

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 22, 2009
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Proposed Earnings-Stripping Rules May Affect Canadian Investments in the United States

by Michael J. Miller
Published: The Canadian Tax Journal, September 01, 2007
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Accessing U.S. Income Tax Treaties: Current Trends in the Limitation on Benefits Article

by Michael J. Miller
Published: International Tax Journal, June 01, 2007
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Notice 2007-13 Announces New and Improved Substantial Assistance Rules

by Michael J. Miller
Published: Tax Management International Journal, April 13, 2007
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Proposed Regulations 'Clarifying' the Technical Taxpayer Rule Don't Pass the Giggle Test

by Howard J. Levine, Michael J. Miller
Published: International Tax Journal, February 01, 2007
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Cleansing the PFIC Taint Just Got Easier: New Regulations Permit Purging Elections for Closed Years

by Michael J. Miller
Published: Tax Management Memorandum, April 03, 2006
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Pending Protocol Will Prevent Inverted Corporations from Accessing the Barbados Treaty

by Michael J. Miller
Published: Tax Management International Journal, November 12, 2004
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American Jobs Creation Act of 2004 International Tax Provisions

by Mark David Rozen, Joseph Lipari, Michael J. Miller
Published: R & H Letter to Clients and Friends, November 11, 2004
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Avoiding U.S. Tax On Foreign Sales To U.S. Customers

by Howard J. Levine, Michael J. Miller
Published: The Metropolitan Corporate Counsel, October 01, 2004
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IRS Issues A Warning To Canadian Law Firms With U.S. Branch Offices

by Sanford H. Goldberg, Michael J. Miller
Published: The Canadian Tax Journal, March 01, 2004
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September 15th Due Date for Waiver of Filing Deadline for Foreign Taxpayers

by Mark David Rozen, Michael J. Miller
Published: R&H Letter to Clients and Friends, August 14, 2003
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Proposed Transportation Regulations - Suggestions for Final Course Correction

by Sanford H. Goldberg, Michael J. Miller
Published: Tax Management International Journal, May 09, 2003
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U.S. Export Taxation, Treaty Challenges, and Filing Leniency Bear Watching

by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, March 15, 2002

What to Expect in the New US-Canada Treaty

by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, December 15, 2001

Accessing the Manufacturing Exception to Subpart F Through Contract Manufacturing Arrangements

by Howard J. Levine, Michael J. Miller, Peter A. Glicklich
Published: Journal of Taxation of Global Transactions, December 01, 2001

Appeals Court Invalidates US-Netherlands 'Double-Dip' Financing Structure

by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, October 01, 2001

IRS Proposes Regulations on Treaty Benefits for Payments by 'Reverse Hybrid' US Entities

by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, June 01, 2001

Appeals Court Adheres To Precedent, Tells IRS That It's Too Late To Issue Regulations

by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, February 01, 2001