Carol P. Tello

Carol Tello is a member of Sutherland’s Tax Practice Group and focuses primarily on international tax matters. Her practice includes a broad range of cross-border tax planning and Internal Revenue Service (IRS) controversy matters for both business entities and individuals. Much of her work has been for insurance companies in the cross-border context. She has particular 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.

Her prior experience includes service in the IRS Office of Associate Chief Counsel (International) and as a Special Assistant to the Assistant Commissioner (International). While at the IRS, she participated in a number of income tax treaty negotiations, was the IRS National Office adviser in several 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 TMP 915-3 Payments Directed Outside the United States - Withholding and Reporting Provisions Under Chapters 3 and 4, as well as numerous articles on various tax issues. She also has been recognized in Euromoney’s The Guide to World’s Leading Tax Advisers (2011).

REPRESENTATIVE EXPERIENCE

Carol’s extensive representative experience includes:

• Working with U.S. multinational corporations on cross-border business restructurings.
• Serving as technical adviser in litigation regarding foreign tax credit generator issues.
• Working with foreign multinational corporations on U.S. acquisitions.
• Working with foreign multinational corporations on permanent establishment/U.S. trade or business issues.
• Working with foreign governments concerning U.S. investments, including U.S. real property.
• Working with foreign governments concerning U.S. tax issues of their employees and successfully representing them before the IRS on these and other related matters.

PROFESSIONAL HONORS AND AWARDS

• Recognized in The Guide to World’s Leading Tax Advisers (2011)
• Elected as a Fellow of the American College of Tax Counsel (2011)

• M.L.T., Georgetown University, 1983
• J.D., University of Maryland School of Law, 1981
• B.A., College of William & Mary, 1968

• District of Columbia
• Maryland