Pamela A. Fuller

Pamela A. Fuller

Of Counsel

(646) 201-9100


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Practice Areas
  • Tax Law
Practice Locations
  • Manhattan, NY

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

  • 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
  • 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 or project manager Alex Peters,
  •  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:

  • 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
  • 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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