Michael J. Miller has provided U.S. tax advice to domestic and international clients for more than 25 years. Working with foreign clients, he has structured inbound U.S. investments and operations to avoid the creation of a U.S. permanent establishment and developed structures designed to take advantage of U.S. income tax treaties, the withholding tax exemption for portfolio interest, and other special rules for minimizing U.S. tax. This includes consideration of various anti-abuse rules, such as earnings-stripping limitations and restrictions on the ability to engage in treaty shopping or earn income through hybrid entities. He has worked with U.S. multinationals to structure their foreign investments and operations so as to minimize the impact of certain restrictions on outbound transfers and anti-deferral rules applicable to shareholders of controlled foreign corporations and passive foreign investment companies, as well as maximize the utilization of foreign tax credits. Michael is currently President of the International Tax Institute. He also is co-Chair of the New York University Summer Institute in Taxation: Introduction to International Taxation and Advanced International Taxation. Michael is a former Chair of the U.S. Activities of Foreign Taxpayers Committee of the American Bar Association Tax Section and the Taxation of Business Entities Committee of the New York City Bar. Michael is designated as a leading tax professional in numerous publications, including Chambers USA, Super Lawyers, and Legal Media Group's Expert Guides: Tax Advisors.