Pamela A. Fuller is a corporate and international tax attorney, with over two decades of experience. She advises a wide range of clients–including private and public companies, joint ventures, private equity and hedge funds, C-Suite executives, private U.S and foreign individual clients, and government entities–on transactional, investment, and supply-chain strategies to achieve optimal tax and business results.
Pamela provides sophisticated tax planning services across most industry sectors, including financial services, real estate development, healthcare, pharmaceutical, construction & engineering, infrastructure, oil & energy, retail, and myriad software and emerging digital technologies and services, including those related to crypto currency, tokenization, innovative blockchain applications and solutions, and all aspects of U.S. and foreign tax planning for digitized transactions and assets.
Pamela is also a seasoned taxpayer advocate, with years of experience resolving complex U.S. federal, state, and foreign tax controversies. She is skilled at defending taxpayers before the U.S. Internal Revenue Service at the exam, audit, and administrative appeals levels. If going to court is advantageous, Pamela provides effective and skillful tax counsel.
Pamela is Chair of the American Bar Association (ABA) Tax Section’s Tax Policy Committee, and also Co-Chair of the International Tax Committee of the ABA’s International Law Section, with global membership. She frequently speaks at law conferences, and publishes papers on international tax topics in peer-reviewed law journals. She serves on several steering committees and boards, including TaxLaw 360’s International Tax Advisory Board; the New York State Bar’s “Global Law Week”; and the International Fiscal Association’s prospective New York Congress. Pamela is a founding member of the New York City Bar’s “Taskforce on the Independence of Lawyers and Judges” and a Fellow of both the American Bar Foundation and the American College of Tax Counsel. In 2019, Pamela was recognized as one of 100 Influential Women in International Tax Law.
Pamela began her legal career at the U.S. Tax Court, serving three consecutive 2-year terms as an Attorney Advisor to the U.S. Tax Court’s Chief Judge, handling large “tax shelter” cases and transfer pricing disputes, amongst other issues. Pamela holds an LL.M. in Tax Law from New York University School of Law, where she served as Graduate Editor of NYU’s international law review, and completed post-LL.M. studies in international business and comparative securities law; a J.D. from Seattle University; and a B.A. from the University of Washington. Pamela is admitted to practice law in several U.S. state jurisdictions and multiple federal courts, including the U.S. Tax Court.
Prior to becoming an attorney, Pamela worked as a business news reporter and anchor for a highly regarded NBC News affiliate in Seattle, covering international and emerging tech businesses, and geo-political developments. In this capacity, Pamela had the opportunity to conduct in-depth interviews with the founders and executives of some of the world’s most innovative and successful companies.
Court & Bar Admissions
New York University School of Law – New York, NY
Georgetown University Law Center – Washington, D.C.
Seattle University School of Law – Seattle, Washington
University of Washington – Seattle, Washington
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.
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.)