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—a structure that 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 Internal Revenue Service on affordable housing issues and has authored or participated in a number of groundbreaking private letter rulings in the tax-exempt bond, real estate investment trust (REIT) and low-income housing tax credit fields.
