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Hogan Lovells US LLP

COLUMBIA SQUARE, 555 THIRTEENTH STREET, NW, WASHINGTON DC 20004, USA
Tel:
Work +1 202 637 5600
Fax:
Fax +1 202 637 5910
Email:
Web:
www.hoganlovells.com

Todd Miller

Tel:
Work 202 637 5667
Email:
Hogan Lovells US LLP

Position

Todd Miller is a member of Hogan Lovells’ tax practice group. His practice encompasses a broad range of matters with particular emphasis on tax controversies, transfer pricing, international tax planning and corporate acquisitions, dispositions and reorganizations. He also serves as Hogan Lovells’ tax matters partner. Todd’s tax controversy work involves representing domestic and international clients in tax audits, and appeals before the IRS, in mediation and in litigation. Todd’s practice before the Internal Revenue Service also involves such matters as ruling requests, requests for extensions of time to file elections, and closing agreements.

Career

J.D., Order of the Coif, Duke University School of Law, 1971; B.A., Phi Beta Kappa, The State University of New York, University at Buffalo, 1969.

Member

Tax Section, American Bar Association.


United States: Tax

US taxes: contentious

Within: US taxes: contentious

Hogan Lovells US LLP is led by team head Siobhan Rausch, Todd Miller and Christine Lane, who are all based in Washington DC. Rausch specializes in securing IRS private letter rulings for clients and handles complex tax-exemption applications. Miller is an IRS audits and appeals expert and also acts for clients before the IRS on ruling requests, refund claims, technical advice requests, and closing agreements. Lane also advises on complex controversy matters.

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Legal Developments by:
Hogan Lovells US LLP

  • Hong Kong Enacts Competition Law

    After years of debate, on 14 June 2012 and in its last days of office, the Legislative Council finally enacted Hong Kong’s first cross- sector competition law.
    - Hogan Lovells

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  • CommuniquĂ© on Equity Crowdfunding Is Officially Published

    By way of background, in January 2019, the Capital Markets Board (“ CMB ”) had issued an announcement on its website on the Draft CommuniquĂ© on Equity Crowdfunding [1] . The CMB has now officially published the CommuniquĂ© on Crowdfunding No. III-35/A (“ CommuniquĂ© ”), on October 3, 2019. The CommuniquĂ© entered into force as of October 3, 2019.
  • Beneficial Ownership Concept new interpretation from the Russian federal tax service

    The recent interpretative letter issued by the Russian Federal Tax Services (“FTS”) on 08th August 2019, has provided further guidance as to the application of the Beneficial Ownership Concept, further to the letter initially provided on the 12th of April 2018 which adopted a strict approach of the concept. 
  • Cyprus and Netherlands Double Tax Treaty Update

    Cyprus has concluded the negotiations for the avoidance of double taxation with the Netherlands. The double tax treaty was agreed at technocratic level in Hague. It is expected to be signed by the end of 2019 or early in 2020.
  • Vacancy - Senior Corporate Lawyer

    The Senior Corporate Lawyer, who will be reporting to Partners, will be working with both the firm’s legal team as well as the financial services team. The successful candidate will be requested to show initiative, take on certain responsibilities within the firm, work in a multinational environment and will immediately be given the opportunity to further advance their career within the law firm.
  • CJEU RULED ON THE APPLICATION OF THE BENEFICIAL OWNERSHIP CONCEPT

    The judgment of the Court of Justice of the European Union (CJEU) on February 26, 2019, in the “Danish Beneficial Ownership Cases”, can be perceived as a landmark on the interpretation of the Beneficial Ownership concept under the Interest and Royalties Directive (IRD) and the Parent-Subsidiary Directive (PSD).
  • Court of Justice rules on source of income for Derivative Residence applications

    On 2 October 2019, the Court of Justice delivered its judgment in Bajratari v Secretary of State for the Home Department (Directive 2004/38/EC) Case C-93/18 which concerns Chen applications and the source of funds for self-sufficiency. 
  • End of the ‘centre of life test’ in Surinder Singh cases?

    In the recent case of  ZA (Reg 9. EEA Regs; abuse of rights) Afghanistan   [2019] UKUT 281 (IAC ), the Upper Tribunal found that there is no basis in EU law for the centre of life test, as set out in Regulation 9(3)(a) of the Immigration (European Economic Area) Regulations 2016 (the “Regulations”). It further found that it is not to be applied when Judges assess  Surinder Singh  cases that appear before them.
  • ITALIAN RULES ON JOINT VENTURES IN PUBLIC PROCUREMENT AND CONCESSIONS

    Italian rules on jointventures concerning public procurement and concession contracts are set out inlight of the European legal framework provided for in Directive 2014/23/EU and 2014/24/EU of the European Parliament and of the Council. The European rules aim to ensurethe best use of public money so that EU citizens benefit from strategicinvestments and services at fair prices. In this context, public procurementand concessions represent key instruments that need to be regulated and standardisedin order to ensure free movement of goods, freedom of establishment and freedomto provide services.
  • Terms of employment as a sole representative

    In this article we examine the working arrangements of sole representatives, looking at the terms and conditions of employment that the Home Office will expect a sole representative to have in order to qualify as a representative of an overseas business.  
  • Can Sole Representatives Be Shareholders?

    The Immigration Rules require that an applicant for a  sole representative visa  is not “a  majority shareholder in the overseas business”.