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Mark Miller focuses his practice on tax matters, including structuring of corporate, partnership and limited liability company transactions such as formation, joint ventures, acquisitions, dispositions, and reorganizations. Mark is also very active in the representation of tax-exempt organizations on issues relating to reporting compliance, executive compensation, private inurement, intermediate sanctions, and unrelated business taxable income. Mark also has substantial experience in the resolution of federal tax controversies, including the representation of clients in disputes before the U.S. Tax Court, U.S. District Courts, the Internal Revenue Service Appeals and Examination Division, and the Internal Revenue Service National Office.

IRS Releases Guidance on Taxability of Identity Protection ServicesAs companies and governmental entities increasingly do business and store sensitive information in online or cloud-based environments, the risk of improper disclosure continues to grow. The unprecedented breach of the United States Office of Personnel Management’s (OPM) system, in which the personal data of more than 22 million individuals was stolen, was a topic of