- 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.
Counsel,
- Phone: 404.881.7966
- Mobile Phone: 202.495.9809
- Email: miller.williams@alston.com
Multinational corporate clients consult Miller on a national basis regarding complex transfer pricing matters with an emphasis on international transfer pricing controversy, audits, advance pricing agreements (APAs), competent authority (CA), and intercompany planning and structuring.