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Michael R. Miles

Of Counsel

Michael provides insurance companies with creative solutions and tax planning strategies for their corporate, insurance, and reinsurance transactions. 

These include cross-border transactions and corporate restructurings. He 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 Eversheds Sutherland (US), 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.

  • Represented Mutual of America Life Insurance Company, a New York domestic mutual life and annuity insurer, on its acquisition of 100% of the stock of Grandmark Funds, Inc. and its wholly owned subsidiary, Landmark Life Insurance Company.
  • Represented Empower in its acquisition of MassMutual’s retirement services business for a total transaction value of $3.35 billion.
  • Represented Empower in its acquisition of Prudential’s retirement plan business for a total transaction value of $3.55 billion.
  • Advised Symetra Financial Corporation on the sale of its wholly owned subsidiary, Medical Risk Managers, Inc., a managing general underwriter and health care consulting firm, to BCS Financial Corporation.
  • Represented Voya Financial in its sale of individual life and annuity business, including Security Life of Denver, to Resolution Life Group Holdings.
  • Resolved a five-year international investigation on behalf of a global insurer concerning the insurer’s potential liability to the US Department of Justice in connection with cross-border sales of life insurance products by its non-US operating companies.
  • Represented Nationwide Mutual Insurance Company on its acquisition of Jefferson National Financial Corporation and its subsidiaries
  • Canadian Life and Health Insurance Association Inc. Tax Conference, May 17-18, 2017
  • Canadian Life and Health Insurance Association Tax Meeting, May 17-19, 2016
  • Named to The Best Lawyers in America in the area of tax law (2005-2024)
  • Selected for inclusion in Washington, D.C., Super Lawyers® (2008-2015)
  • Member, Tax Section, American Bar Association
  • Member, Tax Section, Federal Bar Association
  • Member, Tax Section, District of Columbia Bar
  • District of Columbia
  • LL.M., with honors, Georgetown University Law Center
  • B.S., with honors, Ohio University,

    Member, Honors College

  • J.D., with honors, The Ohio State University,

    Order of the Coif

Michael Miles

Of Counsel

Michael Miles

Of Counsel

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