Caroline C. Setliffe



With more than 15 years of experience-including a stint as an attorney adviser for the US Tax Court-Caroline Setliffe represents multinational corporations, private equity and insurance companies, and financial institutions in complex tax controversy and litigation matters before the Internal Revenue Service (IRS), and advises clients on a wide range of tax issues associated with their financial transactions and general business activities.

In addition to handling federal tax controversies, Caroline’s practice before the IRS includes representing clients in audits, appeals and other administrative matters, and obtaining letter rulings that address consolidated return issues, disclosure requirements, penalty issues and international tax questions.

With her proficiency in multiple languages, she also frequently counsels clients on the cross-border tax implications of insurance mergers and acquisitions, dispositions, debt financings and restructurings. Caroline has extensive experience in Subchapter K and Subchapter L tax matters, reinsurance and captive arrangements, and discovery-related matters.

Prior to joining Eversheds Sutherland, Caroline worked at large international law firms, where she represented clients in all phases of federal tax controversy matters and counseled on insurance laws, including insurance and reinsurance products and the formation of single parent/group captive insurers.


Legal Alerts

Legal Alert: BEAT, FATCA and Insurance-proposed regulations clarify the application of the BEAT and the treatment of insurance premiums under FATCA (December 21, 2018)
On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued two sets of proposed regulations of importance to insurance companies. One set was the ...

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: IRS and Treasury issue proposed regulations on discounting unpaid losses (November 15, 2018)
On November 6, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued proposed regulations that address amendments to the rules for discounting unpaid losses under ...

Legal Alert: IRS provides IRC 817(h) diversification guidance on a new form of mortgage-backed security to be issued by Fannie Mae and Freddie Mac (October 24, 2018)
On October 16, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-54,1 which addresses the treatment of a new mortgage-backed security under the diversification rules of IRC 817(h). ...

Legal Alert: IRS issues key audit directive for life insurers (September 13, 2018)
The Internal Revenue Service (IRS) Large Business and International (LB&I) division recently released an Industry Director’s Directive (IDD) that provides key guidance for life insurers.1 The IDD is ...

Legal Alert: Insurance Industry Provisions in H.R. 1, the Final Tax Bill (December 21, 2017)
On December 20, 2017, the House and Senate passed the final revised version of H.R. 1 (the Final Bill), which was the result of a conference agreement between the House and the Senate in connection ...

Legal Alert: Tax Cuts and Jobs Bill Update, November 14: Major Insurance Industry Changes (November 14, 2017)
As noted in a previous Eversheds Sutherland Legal Alert, on November 2, the House Ways and Means Committee released the “Tax Cuts and Jobs Act” (H.R. 1) (the House Bill). An amended version of the ...

Legal Alert: Tax Cuts and Jobs Bill: Major Insurance Industry Changes (November 8, 2017)
On November 2, 2017, the House Ways and Means Committee released the “Tax Cuts and Jobs Act” (H.R. 1) (the Bill). The Bill already has been amended and likely will undergo further revision before it ...


Altera: Rattling the IRS’s Sense of Comfort in its Rule-Making Process (October 15, 2015)
Bloomberg BNA, US Income Tax Advisory Board

If it Quacks Like a Duck ... A Closer Look into Microcaptives: Tax Dodge or Government Sanctioned Risk Management Tool? (August 5, 2015)

En garde! The Brave New World of Audits: Strategies for Putting your Best Foot Forward vis a vis Disputes with the IRS (July 29, 2015)

Tax Controversy and the Compliance Assurance Process: How to Resolve Disputes Efficiently and Effectively at IRS Appeals (November 14, 2014)
39th Annual Insurance Tax Conference

Insurance & Reinsurance Transfer Pricing - Preparing for Tomorrow’s Tax Challenges Today (November 2013)
BNA Webinar


In the News

Weekly Wrap Up - Caroline Setliffe (August 27, 2017)
National Law Journal
Caroline Setliffe is mentioned in this National Law Journal article for joining Eversheds Sutherland’s Tax Practice Group as counsel in the Washington DC office. The article discusses that Caroline ...

People on the Move - Caroline Setliffe (August 21, 2017)
CityBizList - Washington DC
Caroline Setliffe is featured in this Washington CityBizList article for joining Eversheds Sutherland's Tax Practice Group as counsel in the Washington DC office.

Press Releases

Eversheds Sutherland Adds Counsel Caroline Setliffe, Continues Expansion of Tax Practice in Washington DC (August 21, 2017)
WASHINGTON-Eversheds Sutherland is pleased to announce that Caroline C. Setliffe has joined the Tax Practice Group as counsel in the Washington DC office. Prior to joining Eversheds Sutherland, Ms. ...

Areas of Practice (6)

  • Tax
  • Tax Controversy & Litigation
  • Federal Tax
  • Insurance Finance
  • Insurance Taxation
  • Reinsurance

Education & Credentials

Contact Information:
202.383.0809  Phone
202.373.6001  Fax
University Attended:
Virginia Polytechnic Institute and State University, B.A., cum laude
Law School Attended:
Georgetown University Law Center, LL.M.; Syracuse University College of Law, J.D.
Year of First Admission:
U.S. Court of Federal Claims; U.S. Tax Court; District of Columbia; Maryland; New Jersey; Virginia; U.S. Supreme Court; U.S. District Court for the District of Puerto Rico

Professional Activities

Member, J. Edgar Murdock (Tax Court), American Inns of Court
Member, American Bar Association
Member, Federal Bar Association

Arabic; Armenian; French

Peer Reviews

This lawyer does not have peer reviews.

*Peer Reviews provided before April 15, 2008 are not displayed.

Washington, District of Columbia

Contact Caroline C. Setliffe

Required Fields

Required Fields

By clicking on the "Submit" button, you agree to the Terms of Use, Supplemental Terms and Privacy Policy. You also consent to be contacted at the phone number you provided, including by autodials, text messages and/or pre-recorded calls, from Martindale and its affiliates and from or on behalf of attorneys you request or contact through this site. Consent is not a condition of purchase.

You should not send any sensitive or confidential information through this site. Emails sent through this site do not create an attorney-client relationship and may not be treated as privileged or confidential. The lawyer or law firm you are contacting is not required to, and may choose not to, accept you as a client. The Internet is not necessarily secure and emails sent though this site could be intercepted or read by third parties.