Ms. Pamela Fuller’s practice has a triple focus: tax planning, tax controversies, and tax compliance. She advises a wide range of clients–including private and public companies, joint ventures, funds, high-net-worth individuals, C-Suite executives, and government entities–on transactional, investment, and supply-chain strategies to achieve optimal tax and business results.
She advises clients on both purely domestic transactions and transnational ones, helping both U.S.-based companies and foreign companies (and their executives) achieve the best possible results from a tax and business perspective. As a seasoned practitioner and tax technician, Ms. Fuller is accustomed to handling nuanced matters involving highly technical questions of law, policy, and procedure at the federal, state, and international levels.
She provides sophisticated tax planning services across many industry sectors, including financial services, software & digital technologies, real estate development, healthcare, bio-pharma, construction & engineering, infrastructure, oil & energy, and retail. She understands the exigencies of business and can develop sound, practical solutions that serve both tax accounting and financial accounting objectives.
Ms. Fuller is an effective and assertive taxpayer advocate, with nearly two decades of experience resolving tax controversies involving federal, state, and foreign taxes, as well as tax penalties. She has effectively represented clients in IRS audits and at IRS appeals. When going to court is the best strategy, she is able to guide her clients through the complex litigation process.
She is a skilled negotiator, and has helped clients achieve attractive out-of-court settlements. Some of the controversies Ms. Fuller has handled have involved novel questions of law. She also has significant experience with complex transfer pricing issues–skills first acquired when she clerked for the United States Tax Court, serving three consecutive 2-year terms in the Chief Judge’s chambers in Washington, D.C.
Ms. Fuller publishes articles on current tax and international law topics, and has frequently served as a session rapporteur in connection with international tax seminars sponsored by the International Bar Association. She regularly speaks at tax and international law conferences, and is slated to chair an in-depth presentation on the international tax planning issues and opportunities raised by the Tax Cuts & Jobs Act of 2017, being held in New York City during Global Law Week 2018.
Ms. Fuller holds an LL.M. in Tax Law from New York University School of Law, a J.D. from Seattle University, and an B.A. from the University of Washington. Earlier in her legal career, Ms. Fuller completed judicial clerkships at both state and federal courts.
Prior to becoming a tax attorney, Ms. Fuller worked as a business new reporter and anchor for a highly regarded NBC News affiliate in Seattle. When she is not practicing tax law, speaking and writing articles on international law, Ms. Fuller loves to snow ski, hike, and travel.
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