- The Ohio State University Michael E. Moritz College of Law, J.D., 2000
- The Ohio State University, B.S., 1997, summa cum laude
Bar & Court Admissions
- United States Tax Court
- Admitted to practice law only in the states listed above.
Jeff is of counsel in the Vorys Columbus office and a member of the tax group. He regularly advises business and individual clients in federal income and employment tax matters regarding:
- the permissibility of federal income and employment tax return positions
- tax compliance and procedures
- the federal income and employment tax consequences of proposed transactions
- alternative structures to minimize federal income and employment tax liability
Jeff assists clients with employment tax reporting and withholding and regularly advises clients’ in-house or external accountants during income or employment tax audits. He represents clients before the Internal Revenue Service in cases of disputed liability involving federal income tax, federal employment tax, federal excise tax and several types of civil penalties both at audit and before the Internal Revenue Service Office of Appeals. Jeff also has represented taxpayers in federal excise tax disputes before the Alcohol and Tobacco Tax and Trade Bureau. He routinely assists the firm’s state and local tax subgroup in litigation involving various state and local tax disputes, and he has appeared before the Ohio Board of Tax Appeals and the Supreme Court of Ohio.
Jeff is a six-year veteran of the United States Naval Nuclear Power Program where he served on a fast attack submarine. He specialized in integrated operation of power plant systems, and further specialized in chemistry and radiologic control. He has worked in his tax practice with public utilities, industrial power producers and other major manufacturers to obtain and defend function-based state personal property and sales tax exemptions for various equipment. Additionally, Jeff has advised clients regarding federal tax credits available for power production activities.
His notable experience includes:
- Analyzing federal income tax issues involving complex business structures for transactions exceeding $1 billion
- Successfully defending more than $60 million of assessed federal civil tax penalties
- Integral involvement in taxpayer victories at the Supreme Court of Ohio in Newman v. Levin, 120 Ohio St.3d 127 (2008), Beaver Excavating et al. v. Testa, 134 Ohio St.3d 565 (2012), and Gesler et al. v. City of Worthington Income Tax Board of Appeals et al., 2013-Ohio-4986 (2013)
Jeff received his J.D. from The Ohio State University Michael E. Moritz College of Law and his B.S. in business administration/accounting summa cum laude from The Ohio State University.
- 2/23/2018The Vorys Economic Development Incentives Conference was held on February 23, 2018 in Columbus, OH.
- 9/8/2020Dave Froling and Jeffrey Miller, attorneys in the Vorys Columbus office and members of the state and local tax group, authored an article for Tax Law360 titled “Ohio Remote-Work Tax Bills Would Unduly Burden Employers.”
- 8/14/2020State and Local Tax Alert: Ohio Senate Bill 352 Introduced to Remove Pro-Employer Local Withholding Tax Rule Enacted for COVID-19 State of EmergencyLast March, shortly after Governor DeWine required all non-essential employees to work from home, the Ohio General Assembly wisely enacted HB 197 in order to prevent an administrative nightmare for employers.
- 6/8/2020Federal Tax Bulletin: PPPFA Eliminates Restriction on Ability of PPP Loan Recipients to Defer 2020 Employer Social Security Tax PaymentsEmployers with PPP loans forgiven are now fully eligible to take advantage of Employer Social Security Tax deferral.
- 5/4/2020The IRS has issued FAQs providing additional guidance on several aspects of the CARES Act Employee Retention Tax Credit.
- 5/1/2020Federal Tax Bulletin: IRS Concludes That Employer Expenditures Eligible for PPP Loan Forgiveness Are Not DeductibleOn April 30 the IRS issued Notice 2020-32, which concludes that where an employer obtains forgiveness of an amount of a PPP loan, the employer may not claim a tax deduction for the eligible expenditures resulting in such forgiveness.
- 4/23/2020Congress Passes Bill Extending Small Business Loan Programs and Providing Emergency COVID-19 Response FundingFollowing weeks of negotiations, today Congress passed the Paycheck Protection Program and Health Care Enhancement Act providing a relief from the widespread economic injury caused by the COVID-19 public health emergency.
- 4/14/2020As with all aspects of Federal COVID-19 relief, guidance on claiming federal tax credits and deferring payroll tax liability is rapidly evolving and is subject to change. The following provides an outline of guidance on these issues as of the date of this alert.
- 4/1/2020In addition to the CARES Act, a number of states have enacted legislation, implemented relief programs, or made available state resources to further assist businesses in combating mounting economic hardships. This alert summarizes the state-specific relief efforts in Ohio, Pennsylvania, Texas, and Washington, D.C.
- 3/31/2020The CARES Act includes a number of tax provisions designed to provide tax relief to businesses and business owners. One such benefit is a refundable tax credit available to certain employers for wages paid during periods of partial or complete shutdown, or significant decline in gross receipts, resulting from COVID-19.
- 3/30/2020In response to the COVID-19 crisis, Ohio Governor Mike DeWine signed House Bill 197 into law on March 27, 2020, a bill that had passed unanimously in the Ohio General Assembly.
- 3/26/2020Following days of often tense negotiations, the United States Senate has passed the third phase of federal coronavirus relief legislation, the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), which will provide $2 trillion in economic aid to individuals and businesses impacted by the coronavirus public health emergency.
- 3/20/2020Since the first known case of COVID-19 in the United States was discovered in late January, the federal government has taken several steps to both fight the spread of the disease and blunt its economic impact on the American economy.
- 10/4/2018Client Alert: Have You Recently Been Assessed Federal Civil Penalties for Late-Filed or Incorrect Forms W-2? We Should Talk.If your company has outstanding assessments or has paid federal civil penalties for Form W-2 compliance failures within the last two years, please call us.
- 8/1/2018Vorys attorneys Tom Fusonie, Suzanne Galyardt, and Jeff Miller co-authored an article for Ohio Farmer titled “Considerations When Faced With Eminent Domain.”
- 1/5/2018Beginning in 2018, an individual taxpayer generally may deduct 20% of his or her share of “qualified business income” from a U.S. trade or business operated through a partnership (including an LLC treated as a partnership for federal income tax purposes), S corporation, or sole proprietorship (including an LLC treated as a disregarded entity for federal income tax purposes) (the QBI Deduction).
- 1/2/2018The Tax Cuts and Jobs Act (the “Act”) was signed into law on December 22.
- 12/29/2017The Tax Cuts and Jobs Act (the “Act”) was signed into law on December 22. The Act brings about immediate, sweeping changes to the federal income tax laws, affecting businesses and business owners across all industries. Most provisions of the Act are effective for taxable years beginning after December 31, 2017. Certain provisions, however, are retroactive to September or November of 2017.
- 11/18/2016On November 1, 2016, the Internal Revenue Service (IRS) issued Notice 2016-66. The Notice designates certain so-called “micro-captive” insurance company transactions as “transactions of interest” for purposes of Treas. Reg. Sec. 1.6011-4(b)(6), Code Sec. 6111, and Code Sec. 6112.
- November/December 2014It’s Time to Update Your Tax Sharing Agreement – And If You Do Business in Ohio You’ll Need a Second OneDave Froling and Jeffrey Miller, attorneys in the Vorys Columbus office and members of the tax group, co-authored an article titled “It’s Time to Update Your Tax Sharing Agreement – And If You Do Business in Ohio You’ll Need a Second One” for the November/December 2014 edition of the Journal of Taxation and Regulation of Financial Institutions.
- Fall 2014The Ohio Supreme Court Decides Two Important Municipal Income Tax Cases Involving the Ohio ConstitutionDave Froling and Jeffrey Miller, attorneys in the Vorys Columbus office and members of the tax group, co-authored an article titled “The Ohio Supreme Court Decides Two Important Municipal Income Tax Cases Involving the Ohio Constitution” for the Fall 2014 edition of the Journal of State Taxation.
- 11/22/2013State and Local Tax Alert: Ohio Supreme Court Issues Decision Holding the Ohio General Assembly’s Constitutional Powers Do Not Trump Worthington’s Constitutional Power to Levy TaxesThe Vorys state and local tax group scored an important municipal income tax victory for taxpayers. The decision also helps clarify a complex area of Ohio Constitutional law. Gesler et al. v. City of Worthington Income Tax Board of Appeals et al. involved competing Ohio Constitutional provisions. On one hand, the Ohio Constitution confers upon home rule municipalities all powers of local self-government which includes the power to levy taxes. On the other hand, the Ohio Constitution confers upon the Ohio General Assembly the power to limit home rule municipalities’ power to levy taxes.
- 10/7/2013Labor and Employment Alert: IRS Guidance on Employment Tax Refunds for Health Benefits Provided to Same-Sex SpousesOn September 23, 2013 the IRS issued Notice 2013-61. The Notice sets forth streamlined refund procedures for overpayments of federal employment taxes paid by employers and employees relating to health benefits provided to legally married same-sex spouses. The Notice addresses health benefits provided both in 2013, and prior open years. The IRS had previously released Revenue Ruling 2013-17 setting forth its position that same-sex partners legally married under the laws of any state would be considered married for federal tax purposes regardless of where the couple resides. Under this state of celebration standard, the laws of the state where the marriage was celebrated (rather than the state of domicile) governs marital status for federal income tax purposes.
- 12/18/2012State and Local Tax Alert: Vorys Wins Ohio Tax Case for Clients, Ohio Supreme Court Issues Decision in Beaver Excavating Co. v. Testa, $140 Million in Annual Gross Receipts Tax Proceeds Derived From Sales of Motor Vehicle Fuel Must be SpentOn December 7, 2012, the Supreme Court of Ohio ruled in favor of a coalition of businesses and county engineers that Ohio commercial activity tax (CAT) revenue derived from sales of gasoline and other motor vehicle fuels must be spent for highway purposes.