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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.

by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, August 4, 2017
Download the file for Foreign Corporation Not Taxable on Redemption of Partnership Interest: Tax Court Rejects Rev. Rul. 91-32.
by Ellen Seiler Brody, Michael J. Miller
Published: Bloomberg BNA Daily Tax Report, August 3, 2017
Download the file for Reliance on a CPA As Reasonable Cause:
by Michael J. Miller, Ellen Seiler Brody, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 24, 2017
Download the file for 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
Published: Canadian Tax Journal, August 1, 2014
Download the file for Snowbirds Flying Blind: Beware the US Residence Trap.
by Michael J. Miller
Published: The Canadian Tax Journal, October, 2013
Download the file for Options to Consider for Non-US Investors in US Real Estate.
by Michael J. Miller, Ellen Seiler Brody
Published: International Tax Journal, March 5, 2013
Download the file for Expats Live in Fear of Malevolent Time Machine.
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
Download the file for IRS Provides Detailed Guidance on 2012 Offshore Voluntary Disclosure Program and Announces New Alternative Procedure for Certain Taxpayers Living Abroad.
by Michael J. Miller, Ellen Seiler Brody
Published: International Tax Journal, May-April, 2012
Download the file for Foreign Asset Reporting Under Code Section 6038D.
by Michael J. Miller
Published: International Tax Journal, July 01, 2011
Download the file for Shameful Double Taxation of Individual Expatriates.
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, June 22, 2011
Download the file for IRS Modifies 2011 Offshore Voluntary Disclosure Initiative to Reduce Penalties for Certain Participants and Permit Extensions.
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, June 21, 2011
Download the file for 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, Ellen Seiler Brody
Published: Tax Management International Journal, May 13, 2011
Download the file for The 2011 OVDI: Is Voluntary Disclosure Really Better the Second Time Around? .
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, April 06, 2011
Download the file for Highlights of the New FBAR Regulations and Revised FBAR for 2010 Filings Due June 30, 2011.
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, March 02, 2011
Download the file for 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 & Friends, February 09, 2011
Download the file for IRS Announces 2011 Offshore Voluntary Disclosure Initiative With August 31, 2011 Deadline.
by Michael J. Miller
Published: BNA Tax Management - International Journal, August 13, 2010
Download the file for Tax Court Approves Tax-Free Payment of Outbound Guarantee Fees.
by Michael J. Miller
Published: International Tax Journal, May 2010
Download the file for 2010 FBAR Update.
by Michael J. Miller, Peter H. Blessing
Published: Canadian Tax Foundation - 61st Annual Conference, April 01, 2010
Download the file for Foreign Account Tax Compliance Provisions Have Far-Reaching Effect.
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, March 03, 2010
Download the file for IRS Issues Relief from FBAR Filing Obligations for Three Groups.
by Michael J. Miller
Published: International Tax Journal, January 01, 2010
Download the file for Reflections on the Application of Income Tax Treaties to Hybrid Entities That Earn Non-FDAP Income.
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, September 24, 2009
Download the file for 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, July 22, 2009
Download the file for Taxpayers Still Have Time to Resolve Offshore Tax Issues Through the Voluntary Disclosure Program.
by Michael J. Miller
Published: The Canadian Tax Journal, September 01, 2007
Download the file for Proposed Earnings-Stripping Rules May Affect Canadian Investments in the United States.
by Michael J. Miller
Published: International Tax Journal, June 01, 2007
Download the file for Accessing U.S. Income Tax Treaties: Current Trends in the Limitation on Benefits Article.
by Michael J. Miller
Published: Tax Management International Journal, April 13, 2007
Download the file for Notice 2007-13 Announces New and Improved Substantial Assistance Rules.
by Howard J. Levine, Michael J. Miller
Published: International Tax Journal, February 01, 2007
Download the file for Proposed Regulations 'Clarifying' the Technical Taxpayer Rule Don't Pass the Giggle Test.
by Michael J. Miller
Published: Tax Management Memorandum, April 03, 2006
Download the file for Cleansing the PFIC Taint Just Got Easier: New Regulations Permit Purging Elections for Closed Years.
by Michael J. Miller
Published: Tax Management International Journal, November 12, 2004
Download the file for Pending Protocol Will Prevent Inverted Corporations from Accessing the Barbados Treaty.
by Mark David Rozen, Joseph Lipari, Michael J. Miller
Published: R & H Letter to Clients and Friends, November 11, 2004
Download the file for American Jobs Creation Act of 2004 International Tax Provisions.
by Howard J. Levine, Michael J. Miller
Published: The Metropolitan Corporate Counsel, October 01, 2004
Download the file for Avoiding U.S. Tax On Foreign Sales To U.S. Customers.
by Sanford H. Goldberg, Michael J. Miller
Published: The Canadian Tax Journal, March 01, 2004
Download the file for IRS Issues A Warning To Canadian Law Firms With U.S. Branch Offices.
by Mark David Rozen, Michael J. Miller
Published: R&H Letter to Clients and Friends, August 14, 2003
Download the file for September 15th Due Date for Waiver of Filing Deadline for Foreign Taxpayers.
by Sanford H. Goldberg, Michael J. Miller
Published: Tax Management International Journal, May 09, 2003
Download the file for Proposed Transportation Regulations - Suggestions for Final Course Correction.
by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, March 15, 2002
by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, December 15, 2001
by Howard J. Levine, Michael J. Miller, Peter A. Glicklich
Published: Journal of Taxation of Global Transactions, December 01, 2001
by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, October 01, 2001
by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, June 01, 2001
by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, February 01, 2001