Michael Lloyd practices in the areas of tax and employee benefits with a focus on Foreign Account Tax Compliance Act (FATCA), information reporting and withholding on cross-border payments (e.g., Forms 1042 and 1042-S, etc.), backup withholding, employment taxation, the treatment of fringe benefits, cross-border compensation, domestic information reporting (e.g., Forms W-2, 1099, 1095 series returns, etc.), penalty abatement, and general tax planning and controversy matters. Mr. Lloyd advises large U.S. and foreign multinationals regarding compliance with information reporting and withholding issues, as well as a range of other federal and state tax issues. In addition, Mr. Lloyd serves as a managing editor for the firm's Tax Withholding & Reporting Blog, a resource for in-house counsel, tax, accounts payable and payroll professionals seeking information on tax withholding and reporting developments.
Mr. Lloyd recently completed a three-year term on the IRS Information Reporting Program Advisory Committee (IRPAC), during which time he worked with the IRS on FATCA, the Affordable Care Act (ACA or Obamacare) reporting issues, Form 1099-K reporting issues, and civil penalty administration. IRPAC provides a public forum for discussion of relevant information reporting issues of concern between IRS officials and public representatives. He has also testified before the U.S. Treasury Department and the IRS regarding proposed federal tax regulations. In 2005, the ABA Tax Section recognized Mr. Lloyd as a John S. Nolan Fellow.
Prior to joining Miller & Chevalier, Mr. Lloyd was an associate in the Tax practice group of Baker & McKenzie LLP in Washington, D.C. Before that he served as a Tax Manager for a publicly traded multinational, where he managed federal and state tax examinations and appeals, including matters involving foreign taxes. In addition, he performed domestic and international tax planning, including issues related to the repatriation of foreign earnings, U.S. export tax benefits, research credits, and planning for foreign expansion.
Mr. Lloyd has appeared as a guest speaker on IRS Live and at seminars hosted by Thomson Reuters OneSource, Bloomberg BNA | CITE, IRSCompliance, and Networking Seminars. He also speaks before other organizations such as the Tax Executives Institute (TEI), the American Payroll Association (APA), International Accounts Payable Professionals (IAPP), the Blue Cross and Blue Shield Association, the National Association of College and University Business Officers (NACUBO), and the National Restaurant Association.
While at the University of Maryland School of Law, Mr. Lloyd was awarded the Sam Allen Memorial Prize for Leadership and Scholarship, and was named the best oral advocate for the 2000 and 2001 Mugel National Tax Moot Court Competitions.