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David S. Miller
David Miller's practice includes matters relating to the taxation of financial instruments and derivatives, cross-border lending transactions and other financings, international and domestic mergers and acquisitions, multinational corporate groups and partnerships, private equity and hedge funds, bankruptcy and workouts, high-net-worth individuals and families, and public charities and private foundations. Mr. Miller is ranked the top tax lawyer in the United States for the fourth consecutive year by United States Lawyer Rankings, a ranking guide established by a consortium of U.S. corporations. He is listed in Chambers Global's The World's Leading Lawyers, Chambers USA: America's Leading Lawyer, The Best Lawyers in America, and The Legal 500. Mr. Miller was Chair of the New York State Bar Association's Tax Section in 2008. He is a recipient of The Burton Award for Legal Achievement, which recognizes exceptional legal writing, and is a member of the Tax Forum. Mr. Miller has represented well over a hundred charities on a pro bono basis. He has been recognized for his pro bono work by The Legal Aid Society, Legal Services for New York City, and New York Lawyers For The Public Interest. A summa cum laude graduate of the University of Pennsylvania, Mr. Miller graduated from Columbia University Law School, where he was a Notes and Comments Editor of the Columbia Law Review and a Harlan Fiske Stone Scholar. He was a clerk to the Honorable Mary M. Schroeder of the U.S. Court of Appeals for the Ninth Circuit during the year following law school. He received his LL.M. in Taxation from New York University School of Law. Mr. Miller has authored a number of articles, including, "An Alternative to Codification of The Economic Substance Doctrine," 123 Tax Notes 747 (May 11, 2009); "A Progressive System of Mark-to-Market Taxation," 121 Tax Notes 213 (October 13, 2008); "The Federal Income Tax Treatment of Credit Derivative Product Companies," Tax Forum No. 602 (November 5, 2007); "A Progressive System of Market-to-Market Taxation," 109 Tax Notes 1047 (November 21, 2005); "Credit Derivatives: Financial Instruments or Insurance? And Why it Matters," Taxation of Financial Products (Winter 2002); "Distinguishing Risk: The Disparate Tax Treatment of Insurance and Financial Contracts in a Converging Marketplace," 55 Tax Lawyer 481 (Winter 2002); "An Overview of the U.S. Federal Income Tax Treatment of Collateral Debt Obligation Transactions," 17 Journal of Taxation of Financial Institutions 27 (July/August 2001); "Snake in the Box: The Hazards of Policymaking With ‘Anti-Abuse' Rules," 88 Tax Notes 107 (October 2, 2000); "The Strange Materialization of the Tax Nothing," 87 Tax Notes 685 (May 1, 2000); "Reconciling Policies and Practice in the Taxation of Financial Instruments," 77 Taxes 236 (March, 1999); "An Overview of the Taxation of Credit Derivatives" (Chapter) in The Use of Derivatives in Tax Planning (Frank J. Fabozzi & Robert P. Molay, editors) (1998); "Taxpayers' Ability to Avoid Tax Ownership: Current Law and Future Prospects," 51 The Tax Lawyer 279 (1998); "The Tax Nothing," 74 Tax Notes 619 (February 3, 1997); and "The Federal Income Tax Consequences of Guarantees: A Comprehensive Framework for Analysis," 48 The Tax Lawyer 105 (1994).
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