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. Michael currently is a member of Sutherland’s Executive Committee.
Sutherland advises insurance companies in financial services sales.
Sutherland advised several large insurance companies in the purchase or sale of financial services brokers.
Sutherland represents Manulife in restructuring U.S. operations.
Sutherland provided tax advice to Manulife Financial Corporation in the restructuring of its operations in the United States and establishing John Hancock Life Insurance Company (U.S.A.), with approximately $200 billion in assets under management, as its flagship company in the United States.
Sutherland advises on the tax issues in the acquisition of a top financial services company.
Sutherland worked on the tax issues and related restructurings and financings in the acquisition of a $4 billion financial services company.
Awards and Rankings
Named to The Best Lawyers in America in the area of tax law (2005-2014)
Selected for inclusion in Washington, D.C., Super Lawyers® (2011)
Member, Tax Section, American Bar Association
Member, Tax Section, Federal Bar Association
Member, Tax Section, District of Columbia Bar