REPRESENTATIVE EXPERIENCE Michael’s extensive 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 (2005–2010)
PROFESSIONAL AND COMMUNITY INVOLVEMENT
- Member, Tax Section, American Bar Association
- Member, Tax Section, Federal Bar Association
- Member, Tax Section, District of Columbia Bar
RECENT SPEAKING ENGAGEMENTS
- Co-author, “Permanent Subpart F Exemption Proposed, Certain Unresolved Issues Remain,” Tax Management International Journal, Bureau of National Affairs (BNA) Tax Management (forthcoming)
- 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, Canadian Life and Health Insurance Association Tax Officers Annual Meeting (2004–2009)
- Presenter, Southern Federal Tax Institute Annual Conference (2003)