Carol P. Tello: Lawyer with Sutherland Asbill & Brennan LLP

Carol P. Tello

Carol P. Tello
Washington,  DC  U.S.A.

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Experience & Credentials

Practice Areas

  • Tax
  • International Tax
  • Insurance
  • Insurance Taxation
  • Private Investment Funds
  • Federal Tax
Contact InfoTelephone: 202.383.0769
Fax: 202-637-3593
University College of William and Mary, B.A.
Law SchoolGeorgetown University Law Center, LL.M. in Taxation; University of Maryland School of Law, J.D.
Admitted1981, Maryland; 1982, District of Columbia

Professional Activities

Council Director, ABA Section of Taxation

Vice Chair, International Programs - Europe, CLE Committee of the ABA Tax Section

Member, IRS/GWU Advisory Board

Past Immediate Chair, Section of Taxation FAUST Committee, American Bar Association (2011-2013)

Member, Executive Committee, IFA USA Branch

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)

BornWashington, 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.”

Selected Experience

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 Women in Business Law for Tax by Expert Guides (2014-2015)

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, 2014)


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Allocating Section 871(m) Withholding Tax Risk: ISDA Publishes New Protocol Addressing Withholding Under Section 871(m)
Robert S. Chase,Mary E. Monahan,William R. Pauls,Amish M. Shah,Carol P. Tello, November 16, 2015
On November 2, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA 2015 Section 871(m) Protocol (the Protocol) that provides an efficient method to amend existing ISDA Master Agreements to address recently issued final regulations. Under Section 871(m), certain...

Proposed Regulations Dramatically Change U.S. Federal Tax Treatment of Outbound Transfers of Intangible Property
Robert S. Chase,Tess K. Illos,Jennifer B. Molnar,Aaron M. Payne,Carol P. Tello, September 30, 2015
On September 16, 2015, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published proposed regulations under section 367 and proposed and temporary regulations under section 482 that together would significantly change the U.S. federal tax treatment of outbound transfers of...

IRS Targets Use of Basket Option Contracts and Basket Contracts by Hedge Funds and Other Taxpayers as Tax Avoidance Transactions
Robert S. Chase,Daniel R.B. Nicholas,David A. Roby,Rich Sun,Carol P. Tello, July 16, 2015
On July 8, the Internal Revenue Service (IRS) issued two notices (Notice 2015-47, 2015-30 IRB 1, and Notice 2015-48, 2015-30 IRB 1) targeting the use of Basket Option Contracts and Basket Contracts as tax avoidance transactions or possible tax avoidance transactions. Similar transactions have...
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Office Information

Carol P. Tello

700 Sixth Street NW, Suite 700
WashingtonDC 20001-3980


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