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Carol P. Tello

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Carol P. Tello

Carol P. Tello

Partner
Carol P. Tello
 
Sutherland Asbill & Brennan LLP
1275 Pennsylvania Avenue, NW
Washington, District of Columbia  20004-2415


Telephone: 202-383-0100
Fax: 202-637-3593
http://www.sutherland.com



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Experience & Credentials
 


Practice AreasInternational Corporate Taxation; International Mergers and Acquisitions; International Individual Taxation
 
EducationUniversity of Maryland, J.D., 1981; Georgetown University School of Law, M.L.T., 1983, College of William and Mary, B.A., 1968
 
Admitted1982, District of Columbia
 
BornWashington, D.C., January 18, 1946
 
BiographyChair of the Controlled Foreign Corporations and PFIC's Subcommittee of the Foreign Activities of U.S. Taxpayers Committee of the ABA Section of Taxation. Council Member, USA Branch, International Fiscal Association.
 
ISLN903216140
 

Documents by this lawyer on Martindale.com


October Trick or Treats for PFICs
Christopher Ocasal, Carol P. Tello, November 10, 2009
Passive foreign investment companies (PFICs) were the subject of October proposed reporting legislation and an IRS private letter ruling, which provided helpful advice on the PFIC-CFC (controlled foreign corporation) overlap rule under section 1297(d). Both of these developments highlight the fact...

IRS Concludes That U.S. Lending Activities Conducted Through a Dependent or Independent "Agent" Constitute a U.S. Trade or Business
Michael R. Miles, Carol P. Tello, Christopher Ocasal, October 1, 2009
On September 22, 2009, in its first written guidance on the topic, the IRS Chief Counsel's Office issued a memorandum to the IRS's Manhattan Financial Services Office in which the Associate Chief Counsel (International) concluded that interest income from loans made by a foreign lender to a U.S....

New IRS PFIC Rulings, More Guidance Available
Carol P. Tello, Christopher Ocasal, August 20, 2009
On July 22, 2009, John Merrick, Special Counsel to the IRS Associate Chief Counsel (International), spoke at the International Fiscal Association USA Branch meeting in New York. At the meeting, Mr. Merrick indicated, in part, that the IRS had adopted an ad hoc strategy of providing guidance through...



 

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