Law360’s annual Influential Women in Tax awards are based on attorneys’ complex litigation wins, important enforcement work, significant deals, and other career accomplishments.
Significant aspects of Miller’s practice involve complex federal tax controversies, tax issues for closely held entities, state-tax planning issues, and litigation involving e-commerce, cloud computing, and state nexus. She has extensive experience representing individuals, businesses and institutions before the IRS’s offshore voluntary compliance program. Since joining Reed Smith in 2010, she routinely represents ultra-high-net worth individuals before the IRS.
Miller has taken on some of the most complex and high-stakes estate and gift tax cases before the U.S. Tax Court. These cases have involved not only defending her clients’ estate tax positions, but also refuting novel and aggressive positions taken by the IRS.
In one such case, Miller defended estate planning focused on the preservation and succession of a 70-year-old family-owned business. She successfully argued that money an ageing company owner advanced to “dynasty trusts” for the benefit of her sons and future generations (to fund stock purchases to keep her company in the family) should not be regarded as loans still owed to her estate. This groundbreaking decision preserved long-standing gift tax planning techniques of attorneys practicing in this area.
“Kelley has a breadth and depth of a wide array of tax knowledge – from state sales tax to international tax laws – that very few lawyers have,” says Lee Zoeller, head of Reed Smith’s State Tax group. “It’s rare to find lawyers who are comfortable advising clients on complex trust issues one day and state tax apportionment issues the next day.”
Miller is a proud vice chair of the Women’s Initiative Network of Reed Smith (WINRS) for the D.C. and Tyson offices, where she mentors younger women in the practice and helps design programming for women attorneys.
In pro bono work, Miller established the Exonerees Tax Assistance Network, which provides tax assistance to individuals exonerated of crimes they did not commit. This includes working to recover taxes paid on compensation that exonerees received from the federal government because of their wrongful convictions.
In recognition of her pro bono work, Thompson Reuters named Kelley a 2016 Everyday Hero, and in 2018, her clients nominated her as one of the D.C. Bar’s Pro Bono Attorneys of the Year.
Miller serves as an Adjunct Professor of Law at Georgetown University Law Center where she teaches Partnership Tax.
Before entering private practice, Miller served as the attorney advisor to the Honorable Stanley J. Goldberg of the U.S. Tax Court from 2006 through 2008.
In 2017, Reed Smith’s tax team landed recognition from Law360 as a Practice Group of the Year.
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