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Tax Advisers - Deloitte

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United States<br />

Clifford E Muller<br />

Sutherland Asbill & Brennan LLP<br />

1275 Pennsylvania Avenue, NW<br />

Washington, DC 20004<br />

US<br />

Tel: (1) 202 383 0207<br />

Fax: (1) 202 637 3593<br />

Email: cliff.muller@sablaw.com<br />

Website: www.sablaw.com<br />

Cliff Muller practises exclusively in the area of federal tax law and concentrates<br />

primarily on transactions with international tax implications.<br />

Mr Muller’s practice focuses on analysing and structuring international transactions,<br />

including acquisitions, dispositions, reorganizations, transfer pricing, repatriation<br />

techniques, currency transactions and finance company arrangements. He is experienced<br />

in the taxation of financial transactions, including interest rate swaps, currency swaps,<br />

commodity swaps, debt offerings and hedging transactions. Mr Muller works regularly<br />

with the Internal Revenue Service and Treasury Department regarding regulation<br />

projects, formal rulings and informal advice and with Congressional Committee staffs<br />

regarding the technical operation of statutory and bill language.<br />

Mr Muller is a member of the American Bar Association’s Committee on Financial<br />

Transactions and was the committee chairman for the Subcommittee on International<br />

Financial Transactions. He is the author of numerous writings on international tax<br />

subjects, including the BNA portfolio on <strong>Tax</strong> Aspects of Foreign Currency, and speaks<br />

frequently before TEI, the American Conference Institute, the World Trade Institute<br />

and other professional and trade associations. He was an associate professor of law at<br />

the George Washington University National Law Center and taught a course entitled<br />

“Special Problems in Corporate <strong>Tax</strong>ation”, which addressed the issues involved with<br />

taxable and non-taxable mergers, intra-group sales, consolidated returns, liquidations,<br />

net operating loss carryovers and other corporate tax issues.<br />

Mr Muller graduated from George Washington Law School in 1981 with high<br />

honours, and from Bucknell University, magna cum laude, in 1978.<br />

286 Guide to the World’s Leading <strong>Tax</strong> <strong>Advisers</strong>

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