- International Tax
- Insurance Taxation
- Private Investment Funds
- Federal Tax
|Contact Info||Telephone: 202.383.0769|
|University ||College of William and Mary, B.A.|
|Law School||Georgetown University Law Center, LL.M. in Taxation; University of Maryland School of Law, J.D.|
|Admitted||1981, Maryland; 1982, District of Columbia|
Vice Chair, International Programs - Europe, CLE Committee of the ABA Tax Section
Past Immediate Chair, Section of Taxation FAUST Committee, American Bar Association (2011-2013)
D.C. Regional Vice President, USA Branch of the International Fiscal Association (IFA)
fellow, American Bar Foundation
Member, Task Force on International Tax Reform, Tax Section, American Bar Association (which published its report in The Tax Lawyer in 2006
Executive Committee, IFA USA Branch
|Born||Washington, D.C., January 18, 1946|
With a career that spans both government and private practice, Carol Tello helps multinational companies and individuals navigate the complex and rigorous realm of international taxation. Her practice includes a broad range of cross-border tax planning and Internal Revenue Service (IRS) controversy matters, including compliance with the Foreign Account Tax Compliance Act (FATCA).
Balancing the concurrent goals of minimizing tax consequences and complying with the law, Carol brings experience in cross-border restructuring transactions, inbound corporate transactions, withholding matters and treaty interpretation issues, as well as cross-border taxation of corporate executives and the U.S. taxation of non-U.S. citizens. She also advises clients on tax issues involving intellectual property transactions.
Before joining Sutherland, Carol worked in the IRS Office of Associate Chief Counsel (International) and as a Special Assistant to the Assistant Commissioner (International). She participated in a number of income tax treaty negotiations, was the IRS National Office adviser in several U.S. Tax Court cases, and worked on various regulations and other guidance, including significant participation in developing regulations concerning the taxation of software transactions. Carol is the author of the BNA Treatise Payments Directed Outside the United States - Withholding and Reporting Provisions Under Chapters 3 and 4.
Sutherland counsels two U.S. multinationals in IRS foreign tax credit controversy.
Sutherland advises Fortune 200 and a U.S. subsidiary of a large foreign multinational company on preparation for a 1042 audit.
Sutherland serves as tax counsel to a Fortune 100 firm on acquisition of a foreign group and the resulting cross-border business restructuring.
Awards and Rankings
Recognized as one of the top 20 in Tax in the United States in Women in Business Law, a Legal Media Group Guide to the World's Leading Lawyers (2012-2013)
fellow, American College of Tax Counsel
Recognized in The Guide to World's Leading Tax Advisers (2011)
Documents by this lawyer on Martindale.com
Clock Is Ticking...Relief for Late Filed GRAs Expected to Expire Soon
Robert S. Chase,Michael R. Miles,Jennifer B. Molnar,William R. Pauls,Carol P. Tello, May 27, 2014
Time may be running out for taxpayers to correct technically deficient gain recognition agreements (GRAs) under the relief procedure contained in the Directive on Examination Action With Respect to Certain Gain Recognition Agreements, LMSB-4-0510-017 (July 26, 2010) (the Directive). Historically,...
IRS Issues Draft FATCA FFI Agreement and Announces Positive New Rules for Insurance Companies
Dennis L. Allen,Jeffrey H. Mace,Michael R. Miles,M. Kristan Rizzolo,Carol P. Tello, November 4, 2013
On October 29, the Internal Revenue Service (IRS) issued Notice 2013-69, which includes guidance to foreign financial institutions (FFIs) entering into FFI agreements with the IRS and a draft FFI agreement. The Notice also describes some of the changes the IRS intends to make to the recently...
OECD Summarizes Transfer Pricing Documentation Questions Ahead of November Consultation
Robert S. Chase,Mikka Gee Conway,Jennifer B. Molnar,Carol P. Tello,H. Karl Zeswitz, October 11, 2013
The Organisation for Economic Co-operation and Development (OECD) has issued a memorandum in connection with the planned overhaul of transfer pricing documentation rules under its action plan to address base erosion and profit-shifting. The memorandum follows the OECD’s July 30 “White...
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