Ben Miller is a partner at Bennett Thrasher. He leads the firm's Tax Specialty Services Division and Transfer Pricing Practice Area. Ben works with clients to design, implement and/or maintain transfer pricing policies that align strategic business objectives with local and foreign transfer pricing rules and regulations. Ben serves as DFK International's Vice Chair for Transfer Pricing, where he assists with the international coordination and advancement of tax advisory services among member firms.
Recent matter highlights
- Transfer Pricing for REITs: Designed and implemented an efficient approach for allocating shared expenses so the REIT and TRS can apply a single sharing ratio into perpetuity. This approach substantially reduced the administrative resources required to compute quarterly estimated tax payments (the company previously was managing three layers of sharing ratios) and resulted in large permanent tax savings.
- Inbound Investment in Real Estate: Advised European-based private equity on financing structure for inbound investments in U.S. real estate. Enabled client to use commercially reasonable terms for intercompany dealings rather than statutory safe harbours, which helps attract/engage co-investors and better manages tax liabilities associated with the investments.
- Global TP Documentation: Prepared transfer pricing documentation (Master File and Local Files) for historical transfer pricing positions in accordance with the current, dynamic regulatory environments of Malaysia, Singapore, the Netherlands and the U.S. When delivering the documentation to the client, BT presented transfer pricing planning opportunities that reduce the group's annual income tax burden by more than our fees.
Policy design, tax consulting, international tax advisory, US inbound, US outbound, supply chains
Consumer goods and services, industrials, pharma and life sciences, real estate, shipping, tech and telecoms
American Economic Association
PhD (Economics), Georgia State University, 2008
MA (Economics), Georgia State University, 2006
BSBA (International Economics) and BA (Spanish Language), University of Florida, 2004