Pamela A. Fuller, Esq., LLM.

Senior International Tax Counsel

Pamela A. Fuller is a tax attorney with deep expertise in the U.S. tax laws and rules that apply to domestic and foreign corporations, partnerships, limited liability companies, and other pass-through entities—especially in the cross-border M&A context. She advises a wide range of clients–including private and public companies; joint ventures; “start-ups”; private equity and hedge funds; venture capital funds; real estate funds and trusts; family offices; C-Suite executives; and government entities–on investment, growth, and transactional strategies to achieve optimal tax and business results.

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 and often innovative global tax planning strategies and solutions across many industry sectors, including software & emerging digital technologies, financial services, real estate, healthcare, pharmaceutical, construction & engineering, infrastructure, oil & energy, fashion, and on-line retail.

Ms. Fuller is also an effective taxpayer advocate with nearly two decades of experience resolving U.S. federal, state, and foreign tax controversies. Some of the tax disputes Ms. Fuller has handled have involved novel questions of law. She also has significant experience with complex transfer pricing issues–skills she first acquired when serving as Attorney Advisor to the Chief Judge of the United States Tax Court in Washington D.C. for three consecutive two-year terms at the very start of her legal career.

Ms. Fuller is presently the Chair of the Tax Policy & Simplification Committee of the American Bar Association’s (ABA) Tax Section. She is also the incoming Co-Chair of the International Tax Committee of the ABA’s International Law Section. Ms. Fuller often speaks on international tax developments and tax planning strategies at various tax law conferences, including those sponsored by the New York State Bar and American Bar Associations. She writes and publishes in the international tax and securities law areas, and serves as a substantive law review editor of the renowned U.S. International Tax Portfolio series–a leading, authoritative resource for tax professionals, which has been published by BNA (and now Bloomberg) for almost 60 years.

Ms. Fuller serves on several tax-related steering committees, including the technical international tax advisory board of TaxLaw 360, and the New York State Bar Association’s “Global Law Week.”

Prior to becoming an attorney, Ms. Fuller was a business reporter and all-news radio anchor for a highly regarded NBC News affiliate in her hometown of Seattle, Washington, covering geo-political and international business developments, including the emergence and growth of major multinational companies like Microsoft, Starbucks, McCaw Communications, Hewlett-Packard, Nintendo, and Boeing.

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