E. Miller Williams, Jr.

• Led the negotiations in many U.S. – India bilateral APAs, including the first of its kind for a large U.S. multinational company and overall negotiated seven of the 20 agreed U.S-India bilateral APAs along with filing of additional U.S. – India bilateral APA original request and renewals. This included negotiating the first U.S. – India bilateral APA for a large insurance company.
• Negotiated many U.S. – Canada APAs and MAP requests to prevent double tax and, in several cases, sustained all or most the original filing position of the U.S. taxpayer.

E. Miller Williams, Jr. is counsel in the Federal & International Tax Group. His experience with transfer pricing and international tax matters spans almost 30 years. Clients have trusted him with more than 150 advance pricing agreements (APAs), competent authority (CA), mutual agreement procedures (MAP) requests, and transfer pricing audits.

Miller works directly with the IRS’s APMA Program to resolve transfer pricing cases involving a variety of foreign countries including India, Canada, Germany, the UK, Spain, France, Japan, Korea, Luxembourg, and China to resolve transfer pricing disputes. Miller’s clients cover various industries including pharmaceutical, semiconductors, technology, retail, consumer products, motor vehicles, automotive, heavy equipment, industrial machinery, paper and pulp, building products, and energy and power tools.

Miller’s experience also includes providing transfer pricing planning and documentation services to many U.S. multinationals and U.S. subsidiaries of foreign multinationals.

Miller is a frequent speaker at international tax and transfer pricing seminars and has authored numerous transfer pricing articles. Before joining private practice, Miller was a senior attorney in the Office of Associate Chief Counsel (International) and Advance Pricing Agreement Program in Washington, D.C. and was a principal at three nationally recognized accounting firms. Miller also served as an officer and attorney in the U.S. Army JAG Corps, where he served as a prosecutor, defense counsel, and administrative law attorney.

Bar Admissions

• Georgia

Education

• Emory University (LL.M., 1991)
• Stetson University (J.D., 1986)
• Vanderbilt University (B.A., 1983)