Carol P. Tello

Carol P. Tello: Attorney with Eversheds Sutherland (US) LLP
  • Partner at Eversheds Sutherland (US) LLP
  • 700 Sixth Street NW, Suite 700, Washington, DC 20001-3980
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  • Carol P. Tello
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Biography

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 Eversheds Sutherland (US), 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.”

Client Tools

•Opportunity Zones

Experience

“I’ve had the benefit of such different experiences in government and in private practice: in government, making law, and in private practice helping clients comply with the law and achieve a good tax result.”

Experience

Counseled two U.S. multinationals in IRS foreign tax credit controversy.
Advised Fortune 200 and a U.S. subsidiary of a large foreign multinational company on preparation for a 1042 audit.
Served as tax counsel to a Fortune 100 firm on acquisition of a foreign group and the resulting cross-border business restructuring.
Aided foreign governments on U.S. tax matters.
Helped U.S. firms on international restructurings.
Represented Noble Systems in a $200 million recapitalization.
Secured tax-exempt status and advises U.S. organization that raises funds to support British charity.
Represented international insurance company in tax litigation regarding $306 million tax refund.

News

In the News

US Treasury May Limit FTC Branch Intangible Transfer Rule (February 25, 2019)
Tax Notes
Eversheds Sutherland Partner Carol Tello is quoted in this Tax Analysts article discussing the US Treasury’s proposed regulations to limit foreign branch transfers of intangible property issued under ...

Themes in the TCJA Guidance (February 1, 2019)
Tax Notes
Eversheds Sutherland Partner Carol Tello is quoted in this Tax Notes article discussing the Treasury and Internal Revenue Service’s new proposed rules and guidance packages, and the complexity it has ...

CFC Stock Rules Disarm Some Tax Traps but Pitfalls Remain (December 11, 2018)
Law360
Eversheds Sutherland Partner Carol Tello is quoted in this Law360 article discussing the recent proposed CFC stock regulations and the ambiguity it is causing within the industry. At a recent ...

IRS Extends Deadline for Making Section 965 Basis Election (October 8, 2018)
Tax Notes
Eversheds Sutherland Partner Carol Tello is quoted in this Tax Notes article discussing the Internal Revenue Service (IRS) and Treasury’s notice to extend the deadline for making a Section 965 basis ...

Could Mexico's Maquila Regime Change Under U.S. Tax Reform? Maybe (June 28, 2018)
Bloomberg BNA
Eversheds Sutherland Partner Carol Tello is quoted in this Bloomberg BNA article discussing the effects the new corporate tax law could have on global intangible low-taxed income (GILTI) for US ...

TCJA Limits Means For Inversions, But Incentives Remain (April 16, 2018)
Law360
Eversheds Sutherland Partner Carol Tello is quoted in this Law360 article discussing whether the new corporate tax rate, which dropped the corporate income rate from 35 percent to 21 percent, will ...

Grab-Bag Transition Tax Guidance Provides Myriad Answers Answers (April 3, 2018)
Tax Notes
Eversheds Sutherland Partner Carol Tello is quoted in this Tax Notes article regarding the Internal Revenue Service and the Department of Treasury releasing Notice 2018-02, a piece of guidance ...

An Overview of the New International Tax Provisions (February 13, 2018)
Law360
Eversheds Sutherland’s videocast regarding the new Tax Act and how it made significant international tax changes that affect both US and foreign-parented multinational corporations is featured in ...

U.S. Tax Reform Bill's International Provisions Require Quick Action, Practitioners Say (December 19, 2017)
Tax Notes
Eversheds Sutherland Partner Carol Tello is quoted in this Tax Notes article regarding the final international provisions of the US tax reform bill. “One of the changes in the final base erosion and ...

IRS Criminal Investigation Reconsidering Where to Post Attaches (October 16, 2017)
Tax Notes
Eversheds Sutherland Partner Carol Tello is mentioned in this Tax Notes article regarding the Internal Revenue Service’s foreign-posted attaches and how the Criminal Investigation (CI) division is ...

Press Releases

Eversheds Sutherland Partner Carol P. Tello Elected to Executive Vice-President of IFA USA (March 15, 2018)
Eversheds Sutherland (US) LLP is pleased to announce that Partner Carol P. Tello has been elected to serve as Executive Vice President of the USA Branch of the International Fiscal Association, Inc. ...

16 Eversheds Sutherland Partners Named Among the Best in the World by Expert Guides (September 8, 2017)
Eversheds Sutherland is pleased to announce that 16 partners have been selected by Expert Guides as among the best legal practitioners in the world in their respective practice areas. Published by ...

13 Sutherland Partners Named Among the Best in the World by Expert Guides (September 8, 2016)
ATLANTA and WASHINGTON-Sutherland Asbill & Brennan LLP is pleased to announce that 13 partners have been selected by Expert Guides as among the best legal practitioners in the world in their ...

Four Sutherland Partners Named Among the Top “Women in Business Law” by Expert Guides (September 29, 2015)
ATLANTA, NEW YORK and WASHINGTON-Sutherland Asbill & Brennan LLP is pleased to announce that four partners have been selected by Expert Guides as among the top “Women in Business Law” in their ...

Sutherland Partner Carol P. Tello Elected Council Director of the American Bar Association’s Section of Taxation (February 4, 2015)
WASHINGTON-Sutherland Asbill & Brennan LLP is pleased to announce that Carol P. Tello has been selected to serve as Council Director of the American Bar Association’s (ABA) Section of Taxation. A ...

Five Sutherland Attorneys Named Among the Top “Women in Business Law” by Expert Guides (October 16, 2014)
ATLANTA, NEW YORK and WASHINGTON-Sutherland Asbill & Brennan LLP is pleased to announce that five attorneys have been selected by Expert Guides as among the top “Women in Business Law” in their ...

Three Sutherland Attorneys Named Among the Top “Women in Business Law by Expert Guide (July 19, 2012)
NEW YORK and WASHINGTON (July 19, 2012) - Three Sutherland Asbill & Brennan LLP attorneys have been selected by Expert Guides as among the top “Women in Business Law in their respective nationwide ...

Coca-Cola Enterprises Recognizes Sutherland’s Diversity Efforts (July 21, 2010)
ATLANTA (July 21, 2010) - Sutherland Asbill & Brennan LLP has been recognized by Coca-Cola Enterprises (“CCE ) as its primary outside counsel with the highest percentage of women attorneys and ...

Multimedia

Videocast: The importance of understanding section 965 calculations (September 25, 2018)
Not much attention has been paid to the mechanics of the actual calculation of section 965 amounts. It is important to understand the mechanics of section 965 calculations and the inputs, especially ...

Videocast: IP in a new era-aligning business strategy and tax planning for intellectual property (August 2, 2018)
As a result of the OECD’s BEPS project, there is an increased emphasis on aligning income with substantive activity. Former “double country” structures may no longer be viable due to these BEPS DEMPE ...

Videocast: Introduction to International Tax Provisions (February 7, 2018)
The new Tax Act made significant international tax changes that affect both US and foreign-parented multinational corporations. This Bottom Line videocast provides an overview of the provisions, ...

Publications

“It is clear that trade between India and the United States will continue to grow. As that trade grows, the provisions of the income tax treaty between the U.S. and India may no longer reflect the economic relationship and our countries will require a new treaty.”

Legal Alerts

Legal Alert: The Last Piece of the Puzzle-the Section 250 Proposed Regulations (March 12, 2019)
Public Law 115-97 (the Tax Cuts and Jobs Act) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. The Tax Cuts and Jobs Act also added section ...

Legal Alert: We are not in Kansas anymore - OECD proposes way forward for digital tax solution (February 1, 2019)
The Organisation for Economic Co-operation and Development (OECD) has issued a policy note document (Note) addressing the tax challenges of the digitalization of the economy under its action plan ...

Legal Alert: And the BEAT goes on - proposed regulations clarify the application of the base-erosion and anti-abuse tax (December 20, 2018)
On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under section 59A of the Internal Revenue Code of 1986, as amended, ...

Legal Alert: The season of giving - proposed regulations ease FATCA reporting burdens (December 20, 2018)
On December 13, 2018, proposed regulations (Proposed Regulations) were issued that reduce certain compliance obligations under Sections 1471-1474 (the Foreign Account Tax Compliance Act (FATCA)) of ...

Legal Alert: Allocation, apportionment and attribution, oh my - Proposed foreign tax credit regulations provide critical guidance (December 3, 2018)
On November 28, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations concerning foreign tax credit determinations and related issues ...

Legal Alert: INXS? IRS issues proposed regulations under section 163(j) (November 29, 2018)
On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue ...

Legal Alert: Deemed participation better than no participation? Proposed regulations expand tax-free treatment to section 956 inclusions of certain shareholders (November 6, 2018)
On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of ...

Legal Alert: What you need to know about investing in opportunity zones (October 24, 2018)
As part of the Tax Cuts and Jobs Act of 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code, which were intended to promote investments in low-income communities ...

Legal Alert: GILTI by consolidation (September 25, 2018)
Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department ...

Legal Alert: In transition-proposed section 965 regulations incorporate and expand on prior guidance (August 20, 2018)
On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 ...

Articles

OECD Consults on Taxing the Digitalized Economy (March 29, 2019)
Bloomberg Daily Tax Report
On February 13, 2019, the OECD released a public consultation paper titled “Addressing the Tax Challenges of the Digitalisation of the Economy” (Consultation). The Consultation follows the policy ...

Six highlights of DAC6 - A new European Union information reporting regime (Spring 2019)
Partnering Perspectives
US companies with operations in the EU need to know about a new information reporting regime affecting post-June 25, 2018 transactions in order to track those transactions potentially subject to the ...

The Importance of Understanding the Section 965 Calculations (September 24, 2018)
Tax Notes International
Not much attention has been paid to the mechanics of how to calculate section 965 amounts. Although as a practical matter, those calculations will be computed by software, it is still important to ...

States May Escheat IRAs but Who Gets the Tax Bill? (August 22, 2018)
Law360
As state unclaimed property administrators have become more aggressive in recent years, the tax treatment of escheated property has become more consequential. Individual retirement accounts are a ...

Global Tax Transparency for Corporations (Spring 2017)
Partnering Perspectives
Corporations with global operations are now subject to various reporting and disclosure requirements. While know-your-customer rules and anti-money laundering reporting are not new, new requirements, ...

An Introduction to Foreign Tax Credit (April 2016)
Practising Law Institute
In Basic of International Taxation 2016, Sutherland Partner Carol Tello contributed Chapter five. In it, Carol demonstrates the complexity underlying the foreign tax rules and the comprehensive ...

Proposed OECD Multilateral Instrument - Will it be a Game Changer? (July 7, 2015)
TerraLex Connections
In her article for TerraLex Connections, Sutherland attorney Carol Tello discusses Action Item 15 of the BEPS project for developing a multilateral instrument to modify the bilateral network of ...

Study: FATCA Agreement and Intergovernmental Belgian-American: A Diagram (May 1, 2015)
Revue De Droit Fiscal
In the “Study: FATCA Agreement and Intergovernmental Belgian-American: A Diagram,” Sutherland Partner Carol Tello analyzes the impact of the Foreign Account Tax Compliance Act (FATCA). Published in ...

U.S. Tax Obligations and Compliance Options of U.S. Taxpayers (March 25, 2015)
TerraLex Connections
In their article for TerraLex Connections, Sutherland attorneys Carol Tello and Taylor Kiessig address compliance options for U.S. taxpayers, including the recently revised streamlined filing ...

Proposed OECD Multilateral Instrument - Will It be a Game Changer? (February/March 2015)
Scaling BEPS newsletter
In her article for the Scaling BEPS newsletter, Partner Carol Tello discusses Action Item 15 of the Base Erosion and Profit Shifting (BEPS) project, which is to develop a multilateral instrument to ...

Newsletters

Partnering Perspectives: Insights from Inside and Outside the Corporate Law Department (Spring 2019)
We are pleased to present the Spring 2019 edition of Partnering Perspectives. In this issue, we bring you articles that we believe touch the day-to-day lives of many in-house counsel. Each of our ...

Eversheds Sutherland Global Tax Brief (December 2017)
The Eversheds Sutherland Global Tax Brief is a collection of tax developments from our attorneys across the globe. We hope you enjoy this issue of the Brief and look forward to sharing more updates ...

Eversheds Sutherland Global Tax Brief (July 2017)
The Eversheds Sutherland Global Tax Brief is a collection of tax developments from our attorneys across the globe. We hope you enjoy this issue of the Brief and look forward to sharing more updates ...

Partnering Perspectives: Insights from Inside and Outside the Corporate Law Department (Spring 2017)
We are pleased to present the Spring 2017 edition of Partnering Perspectives, which provides insight into a number of developing legal issues with important multinational implications. Articles ...

Books

The Tax Revolution of 2014: FATCA, BEPS, OVDP (2014 )

Payments Directed Outside the United States - Withholding and Reporting Provisions Under Chapters 3 and 4 (2010)
BNA TMP 915-3d

Presentations

“There is significant complexity underlying the foreign tax credit rules and the comprehensive system of regulations that have been enacted over the years not only to ensure that taxpayers are relieved from double taxation, but also to limit claims of credits where double taxation does not exist.”

Presentations

How the TCJA has changed the international tax regime: Then and now Deferral v. current taxation and limited territorial (April 18, 2019)
TEI Detroit International Tax Day
Eversheds Sutherland (US) Partners Carol Tello and Daniel R.B. Nicholas present How the TCJA has changed the international tax regime: Then and now deferral v. current taxation and limited ...

The View From the Other Side: U.S. Tax Considerations for Inbound Investment - BEAT, Section 163(j) limitations, Brexit treaty issues (April 18, 2019)
TEI Detroit International Tax Day
Eversheds Sutherland (US) Partners James Null, Daniel McKeithen and Carol Tello present The View From the Other Side: U.S. Tax Considerations for Inbound Investment - BEAT, Section 163(j) ...

Understanding New Allocation: Maximizing Foreign Tax Credit Benefits, Changes to the Expense Allocation Provisions, and new Section 960 (April 18, 2019)
TEI Detroit International Tax Day
Eversheds Sutherland (US) Partners Carol Tello and Dan R.B. Nicholas present Understanding New Allocation: Maximizing Foreign Tax Credit Benefits, Changes to the Expense Allocation Provisions, and ...

Foreign Tax Credit Panel (February 22, 2019)
IFA USA 2019 Annual Conference
Eversheds Sutherland Partner Carol Tello presents on a Foreign Tax Credit panel at the IFA USA 2019 Annual Conference on February 22, 2019, in Washington DC.

US Developments Relating to Financing and Capital Markets (January 28, 2019)
IBA
Eversheds Sutherland (US) Partner Carol Tello presents US Developments Relating To Financing and Capital Markets at the 8th Annual IBA Finance & Capital Markets Tax Conference on January 28, 2019, ...

Foreign Tax Credits (December 13, 2018)
IRS/GWU Annual International Tax Institute
Eversheds Sutherland (US) Partner Carol Tello presents on the Foreign Tax Credits panel at the IRS/GWU Annual International Tax Institute at the George Washington University Law School on December ...

Restructuring Multinational Groups after the 2017 Tax Act (December 6, 2018)
PLI Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2018
Eversheds Sutherland (US) Partner Carol Tello presents Restructuring Multinational Groups after the 2017 Tax Act at the PLI Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint ...

Eversheds Sutherland Year-End Tax Seminar - Navigating the Changing World of Tax (November 14, 2018)
Eversheds Sutherland (US) attorneys present at the Eversheds Sutherland Year-End Tax Seminar - Navigating the Changing World of Tax on November 14, 2018, in Philadelphia, Pennsylvania. Presentations ...

11th Annual Tax Planning Strategies - U.S. and Latin America (June 13-15, 2018)
American Bar Association (ABA)
Eversheds Sutherland (US) Partners Jim Mastracchio and Carol Tello present at ABA’s 11th Annual Tax Planning Strategies - U.S. and Latin America on June 13-15, 2018, in Miami, Florida. Details of ...

ATAD 1 and 2 with Particular Focus on GAAR and Hybrid Mismatches (April 11-13, 2018)
American Bar Association (ABA)
Eversheds Sutherland (US) Partner Carol Tello presents, “ATAD 1 and 2 with Particular Focus on GAAR and Hybrid Mismatches,” at the ABA European Strategies Conference on April 11-13, 2018, in ...

Awards and Rankings

Eversheds Sutherland (US) has a substantial international tax practice, and nearly 20 lawyers are regularly involved in the planning and controversy aspects of international taxation, including both outbound and inbound transactions.

Recognized in The Guide to World’s Leading Tax Advisers (2011, 2014)

Listed in the International Who's Who of Corporate Tax Lawyers (2013-2014)

Selected for inclusion in Guide to the World's Leading Women in Business Law in tax (2012-2016)

Areas of Practice (6)

  • Tax
  • International Tax
  • Insurance
  • Insurance Taxation
  • Private Investment Funds
  • Federal Tax

Education & Credentials

Contact Information:
202.383.0769  Phone
www.eversheds-sutherland.com
University Attended:
College of William and Mary, B.A.
Law School Attended:
Georgetown University Law Center, LL.M. in Taxation; University of Maryland School of Law, J.D.
Year of First Admission:
1981
Admission:
1982, District of Columbia; 1981, Maryland
Memberships:

Professional Activities

Executive Vice-President, IFA USA Branch
fellow, American College of Tax Counsel
Past Council Director, ABA Section of Taxation
Vice Chair, International Programs - Europe, CLE Committee of the ABA Tax Section
Member, IRS/GWU Advisory Board
Past Chair, Section of Taxation FAUST Committee, American Bar Association (2011-2013)
Member, Executive Committee, IFA USA Branch
Prior 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)
Member, Board of Trustees, American Tax Policy Institute

Birth Information:
Washington, D.C., January 18, 1946
ISLN:
903216140

Peer Reviews

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Documents (32)

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Washington, District of Columbia

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