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® (2008–2011)
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, “You Can’t Spell ‘Subchapter C’ Without E&P: Proposed Treasury Regulations Clarify the Rules Concerning the Allocation of Earnings and Profits in Tax-Free Transfers,” BNA Insights (Federal)—Bloomberg BNA Tax and Accounting Center (April 2012)
n Co-author, “A Secret No More: Final Treasury Regulations Amend the Controlled Group Deferred Loss ‘Supersecret Rule,’” BNA Insights (Federal)—Bloomberg BNA Tax and Accounting Center (April 2012)
- 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)
- Speaker, "Monitoring the Progress of Efforts by Life Insurers to Narrow the Scope of FATCA," FATCA Conference (May 30, 2012)
- 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)