Pamela A. Fuller

Pamela A. Fuller

Of Counsel

(646) 813-2962

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Practice Areas
  • Tax Law
Practice Locations
  • Manhattan, NY

Ms. 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.

NOT ADMITTED TO THE STATE OF NEW YORK BAR. NY PRACTICE LIMITED TO PROVIDING LEGAL SERVICES TO MEMBERS OF THE PUBLIC SOLELY BEFORE A SPECIAL COURT, DEPARTMENT, OR AGENCY OF THE UNITED STATES. ADMITTED TO PRACTICE IN NORTH CAROLINA, THE DISTRICT OF COLUMBIA AND WASHINGTON STATE.

 

Court & Bar Admissions

  • District of Columbia
  • North Carolina
  • Washington State
  • U.S. Tax Court
  • U.S. Court of Appeals for Federal Circuit
  • U.S. Court of International Trade

New York University School of Law – New York, NY

  • LL.M. (in Taxation), 1997
  • NYU Journal of International Law and Politics: Graduate Editor, Articles Editor, Co-Chair of 3-day annual NYU JILP International Law Symposium
  • Post-LL.M. Studies in International Law: Concentrations in international business transactions; international tax; comparative company law, accounting & securities regulation

Georgetown University Law Center – Washington, D.C. 

  • Post-J.D. Graduate Studies, 1992-1994 (while clerking at U.S. Tax Court)

Seattle University School of Law – Seattle, Washington

  • J.D., 1989
  • Cardozo Award
  • Judicial Clerkships (state and federal)
  • Moot Court Team Captain
  • Volunteer Income Tax Association (VITA): Co-Chair
  • Seattle King-County Public Defender’s Office: Law Clerk

University of Washington Seattle, Washington

  • B.A. – Economic History & Editorial Journalism (double major)
  • Full Academic Merit Scholarship – Honors Program
  • The Daily: Editor & Reporter
  • Kappa Alpha Theta Merit Scholar
  • Varsity Athlete
  • Sigma Delta Chi Excellence in Journalism Award
  • Women in Communications Award

Government Experience

  • Attorney Advisor, The Honorable Lapsley W. Hamblen, Jr., Chief Judge of U.S. Tax Court, United States Tax Court, Washington, D.C., 1990 – 1995.
  • Attorney Advisor, The Honorable William M. Drennen, Former Chief Judge of U.S. Tax Court, United States Tax Court, Washington, D.C., 1991-1993
  • Judicial Law Clerk, Washington State Superior Court (highest trial court), Bremerton, Washington, 1989
  • Law Clerk, Seattle-King County Public Defenders’ Office, 1988
  • Upcoming Speaking Engagement — February 28, 2019:  IRC 338(g) Elections for Buyers of Controlled Foreign Corporation Stock in Wake of Major Changes, Strafford Publications (nationwide webinar, Feb. 28, 2019). For tickets to 90 minute presentation, contact Ms. Fuller at pfuller@tullylegal.com or project manager Alex Peters, apeter@tullylegal.com.
  •  Faculty Speaker: “Subpart F Expansion after U.S. Tax Reform”, Strafford Publications (Nationwide webinar on international tax planning in light of the 2017 US Tax Act), Dec. 5, 2018. For more information, including tickets to the on-demand taped presentation, go to:  http://www.sp-04.com/r.php?products/tpet2wfrna

  • Speaker & Moderator: “Transparency Tide or Transparency Tsunami?  The New Wave of Global Reporting Rules and IRS Criminal Investigative Tools to Unearth Foreign Financial Accounts:  FATCA, FBAR, & CRS Developments in the Wake of OVDP and Swiss Bank Program,” ABA Tax Section, Nationwide Webinar, Dec. 12, 2018 and Live at Fall Meeting, Atlanta Georgia, Oct. 5, 2018. (Also available on demand.)

  • Speaker/Panelist: Faculty/Panelist, “Check-the Box Elections for Foreign Subsidiaries:  Achieving Optimal Tax Treatment through Entity Selection in light of the 2017 US Tax Act,”  Strafford Publications (nationwide webinar on cross-border tax planning). June 19, 2018 . (Also available on demand.)

  • Speaker/Panelist:  “A Brave New TAX World for Multinationals: Cross Border Structuring in light of U.S. and Global Tax Law Changes,” June 11, 2018. Panel is part of “Global Law Week” sponsored by New York State Bar Association in Midtown Manhattan, June 11-15, 2018.

  •  Speaker/Panelist: Speaker/Panelist, “Inbound Tax Issues in light of the 2017 U.S. Tax Act, including the § 59A BEAT”  American Bar Association, Section of International Law (international webinar). May 23, 2018

  • Speaker/Panelist: Faculty/Panelist, “Check-the Box Elections for Foreign Subsidiaries:  Achieving Optimal Tax Treatment through Entity Selection in light of the 2017 US Tax Act,” Strafford Publications (nationwide webinar on cross-border tax planning). May 30, 2018. (Also available on demand.)

  • Speaker/Panelist: Fuller is chairing and speaking on an in-person international panel discussing several hot topics in international tax, including the impact of the 2017 US Tax Act on cross-border tax planning and structuring.  Panel is part of “Global Law Week”—sponsored by New York State Bar Association in Midtown Manhattan, June 11-15, 2018.
  • Faculty/Panelist,Section 754 Elections on Form 1065: Making Valid Elections – Seeking Relief for Missed or Invalid Elections,” Strafford Publications (nationwide webinar on partnership taxation), Oct. 11, 2017 (still available as on-line webcast).
  • Speaker/Panelist, “International Tax Issues in Mergers & Acquisition,” ABA International Law Section – Spring Mtg., Wash., D.C., April 26, 2017.
  • Faculty/Panelist, “Check-the Box Elections for Foreign Subsidiaries: Achieving Optimal Tax Treatment through Entity Selection“, Strafford Publications (nationwide webinar on cross-border tax planning), Oct. 20, 2016 (still available as on-line webcast).
  • Faculty/Panelist,Foreign Outbound Transactions Planning: Navigating Deferral under Subpart F and the new IRC 7874, § 367, and § 385 Regulations,” Strafford Publications (nationwide webinar on international tax planning), Aug. 16, 2016 (still available as on-line webcast).
  • Speaker/Panelist, “Key Legal Issues in U.S. Mergers & Acquisitions for European Lawyers,” ABA International Law Section – Europe Forum, Rome, Italy, May 28-29, 2016.
  • Pamela A. Fuller, International Tax – Year in Review 2017 – OECD BEPS Developments – Introduction, Developmments in China, Developments in Japan, __ Intern’l Lawyer __ (2018), ABA Section of Int’l Law & Southern Methodist University School of Law (forthcoming).
  • Pamela A. Fuller (Session Rapporteur), “Structuring the Deal in Light of BEPS (Base Erosion & Profit Shifting Initiatives),” Session Report on presentation by Int’l Bar Assoc.- Corporate/M&A Law Committee and Taxes Committee, Annual Congress of Int’l Bar Assoc., Tokyo, Japan, IBA M&A Committee, Oct. 10, 2015.
  • Pamela A. Fuller (Session Rapporteur): “Debt-Equity Characterization Issues,” Session Report on Taxes Committee Presentation, 3rd Annual IBA/Capital Markets – International Tax Conference, London, England, Oct. 2014.
  • Pamela A. Fuller (Session Rapporteur): “The Use of Partnerships in International Joint Ventures and Other Investments,” (detailed 4-part commentary and report on tax planning with hybrid entities and instruments in cross-border context), Taxes Committee, International Bar Association, Annual Congress, Dubai, 2012.
  • Pamela A. Fuller, The Japan-U.S. Income Tax Treaty: Signaling New Norms, Inspiring Reforms, or Just Tweaking Anachronisms in International Tax Policy?, 40:4 Intern’l Lawyer 773-908 (2006), published by American Bar Assoc. & Southern Methodist University, available at https://www.jstor.org/stable/40708016?seq=1#page_scan_tab_contents
  • Pamela A. Fuller, “Whither M&A in Japan?” New York Law Journal 10-11, April 2005 (Full-page article details Japan’s adoption of Anglo-American styled corporate tax and M&A rules that, at least initially, appeared to incorporate much of Delaware’s hostile takeover jurisprudence. Article also discusses the historic, cultural, and corporate governance reasons behind Japan’s decades-old reluctance to join other industrialized countries in adopting modern cross-border tax and M&A rules).

 

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