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Glenn S. Miller

Washington, DC Office

Glenn Miller brings a creative, problem-solving approach to the tax issues present in a wide range of domestic and international transactions and controversies, including taxable and tax-free acquisitions and dispositions, financing structures (both taxable and tax-exempt), and post-transaction tax planning affecting both buyers and sellers. He has particular experience with structured finance and securitization transactions and transactions involving investments by pension funds, real estate investment trusts (REITs) and tax-exempt organizations in real estate and other income-producing assets. Glenn has represented clients in major controversy matters before the Internal Revenue Service (IRS) concerning federal telecommunications excise taxes, transferee liability, dealer characterization and the acceptability of various accounting methods.

A nationally known authority on affordable housing and historic tax credits, Glenn has substantial experience in the taxation of mixed-use affordable housing projects. He created a tax structure that permitted the first practical syndication of a so-called “80-20” mixed-use low-income project, which is now used in transactions across the country. Glenn also was the primary creator of the “Sub-50 Recycled Bond Structure”—a volume-cap efficient tax-exempt bond structure that is in wide use by the major housing agencies in New York City and New York state. He regularly meets with the IRS on affordable housing issues and has authored or participated in a number of groundbreaking private letter rulings in the tax-exempt bond, REIT and low-income housing tax credit fields.

In addition to his affordable housing and tax-exempt organization work, Glenn advises corporations, partnerships and joint ventures in many other lines of business, including finance, manufacturing, regulated industries (particularly electricity) and high-tech applications such as telecommunications and the Internet. He has extensive experience in the taxation of telecommunications and Internet companies, particularly with respect to federal and state telecommunications excise and sales taxes. Glenn regularly advises telecommunications companies and customers and is one of the few leading authorities on the taxation of prepaid telecommunications debit cards. He has represented a number of clients from a wide range of industries before the IRS in various controversy matters.

Glenn frequently lectures on affordable housing (particularly “80-20” transactions) and on the taxation of the telecommunications industry. He has written articles for various publications concerning debt/equity classification and financial products issues and the federal income taxation of domestic international sales corporations (DISCs) and foreign sales corporations (FSCs).

Shown below is a selection of Glenn’s engagements.


Legal 500, 2015
Glenn S. Miller


  • JD, Harvard Law School, cum laude
  • BS, Louisiana State University, summa cum laude

Bar Admissions

  • District of Columbia

Court Admissions

  • US Tax Court


Legal 500
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