Hogan Lovells US LLP

Tax

Senior Counsel

H. Todd Miller counsels clients concerning their most important tax controversy, transfer pricing, and tax planning matters. He brings to the table a tremendous amount of knowledge and practical experience in resolving tax disputes and in structuring tax-efficient transactions that satisfy his client's business objectives.

Todd has been especially successful in resolving many large tax controversies at the audit and IRS Appeals levels. He also represents clients before the IRS on ruling requests, refund claims, technical advice requests, and closing agreements. When the occasion arises, Todd also represents clients in mediation and litigation.

Todd regularly speaks on transfer pricing matters, and he counsels clients on all aspects of transfer pricing. He advises on intangible property transfers and the pricing of goods and services, and he has been quite successful in resolving transfer pricing disputes with the IRS – both at the IRS Appeals level and through competent authority procedures. Working with the global tax team at Hogan Lovells, Todd regularly advises U.S. businesses on the most tax-efficient means of expanding their foreign operations, and foreign businesses on establishing and expanding their operations in the United States.

Todd also advises domestic and international clients concerning corporate acquisitions, dispositions, and reorganizations – including so-called Morris Trust spin-offs. Before joining Hogan & Hartson (now Hogan Lovells), Todd served as law clerk to the Honorable Charles R. Simpson of the United States Tax Court.

English

Tax Section, American Bar Association

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