John C. Miles
Partner

Admissions
California;
US Supreme Court
Address
525 B Street, Suite 2200, San Diego, CA 92101
Office Tel.
619.906.5650
Fax
619.788.5502
Overview
John C. Miles is a tax and corporate Partner with Procopio. He advises founders, businesses, investors, and high-net-worth individuals on business transactions, tax planning, entity structuring (including strategic joint ventures and matters related to the development of real estate), and exit strategies. John also has significant experience involving S corporation targets, 1202 Stock/Qualified Small Business Stock (QSBS), and transactions in regulated industries (including healthcare and accounting firm targets). He also represents clients in high stakes federal or state tax controversy matters. John was previously a licensed stock broker at a financial firm in San Diego.
- Represented a multi-state, multi-national private company in more than 75 acquisitions to consolidate professional companies in the medical space.
- Represented a regional accounting firm in its sale to private equity firm.
- Represented various Southern California-based companies in their sale to private equity funds or strategic buyers in taxable and tax-free transactions.
- Represented various private real estate developers in acquiring, joint venturing, and developing or redeveloping large-scale residential and hospitality properties.
- Advised on and obtained IRS relief for dozens of invalid S elections.
- JD, University of San Diego School of Law
- LLM, (Taxation), University of San Diego School of Law
- BA, Point Loma Nazarene University
- Co-author. “Selling Your Business? California Residency Could Be One of Your Biggest Tax Issues,” June 17, 2026.
- Author. “5 Action Items Required Now Before Selling Your S Corporation in Two Years,” November 5, 2025.
- Co-author. “IRS Has No Statutory Authority to Assess Penalties for IRS Form 5471,” April 24, 2023. (Spanish version)
- Author. “Request for Guidance Regarding Relevancy Requirement of Check-the-Box Regulations;” California Tax Lawyer, Vol 27, No. 2; August 2018.
- Author. “Request for Guidance Regarding Making Proper S Corporation Consents on Form 2553, Election by a Small Business Corporation;” California Lawyer’s Association Taxation Section; May 2019.
- The Arc of San Diego, Board of Directors, 2023 – present
- Vice-Chair, International Tax subcommittee of the California Lawyers Association
- Adjunct Professor of Business Law, Fermanian School of Business, Point Loma Nazarene University (former)
- Licensed foster and adoptive family
- “Trio of Procopio attorneys elevated to partner,” San Diego Daily Transcript, January 29, 2024.































