Pamela A. Fuller - a New York, New York (NY) Tax Law Lawyer

New York Tax Law Lawyer

Updated: 03/16/2026

Areas of Practice

Tax Law

Attorney Information

Overview

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.

Education

Legal Education

New York University School of Law, New York, New York, 1997
LL.M.
Honors: Co-Chair of 3-day annual NYU JILP International Law Symposium
Honors: Post-LL.M. Studies in International Law: Concentrations in international business transactions; international tax; comparative company law, accounting & securities regulation
Major: Taxation
Law Journal: NYU Journal of International Law and Politics, Graduate Editor, Articles Editor
Seattle University School of Law, Seattle, Washington, 1989
J.D.
Honors: Cardozo Award
Honors: Judicial Clerkships (state and federal)
Honors: Moot Court Team Captain
Honors: Volunteer Income Tax Association (VITA): Co-Chair
Honors: Georgetown University Law Center – Washington, D.C., Post-J.D. Graduate Studies, 1992-1994 (while clerking at U.S. Tax Court)

Non Legal Education

University of Washington, Seattle, Washington
B.A.
Honors: Full Academic Merit Scholarship – Honors Program
Honors: Kappa Alpha Theta Merit Scholar
Honors: Sigma Delta Chi Excellence in Journalism Award
Honors: The Daily: Editor & Reporter
Honors: Varsity Athlete
Honors: Women in Communications Award
Major: Economic History
Major: Editorial Journalism

Current Employment Position(s)

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Of Counsel
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Past Positions

Seattle King-County Public Defender’s Office, Law Clerk
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

Classes and Seminars

Faculty speaker, Section 754 Elections on Form 1065: Making Valid Elections, Seeking Relief for Missed or Invalid Election, CLE & CPE provider: Strafford Publications, August 16, 2022
Faculty speaker, Advanced Tax Considerations in Negotiating, Structuring, and Documenting M&A Transactions, CLE provider: Lorman Institute, August 10, 2022
Faculty speaker, Form 8832 – Check-the-Box Entity Elections Under Section 7701: Selecting Entities for Foreign Operations, CLE/CPE provider: Strafford Publications, July 18, 2022
Faculty speaker, Maximizing the Section 199A Deduction: Increasing Assets and Wages, Separating and Aggregating Businesses, and More, CLE/CPE provider: Strafford Publications, June 13, 2022
Faculty speaker, Targeting Tyrants, Toadies, Tax Evaders, Oligarchs….and the Ostensible Gatekeepers: The New Corporate Transparency Act, FinCEN Proposed Regulations, New U.S. Sanctions Risks, (and why it may be time to become best friends with your “Sanctions Practice” law partner), CLE/CPE provider: American Bar Association, Tax Section, May 13, 2022
Targeting Tyrants, Toadies, Tax Evaders, Oligarchs….and the Ostensible Gatekeepers: The New Corporate Transparency Act, FinCEN Proposed Regulations, New U.S. Sanctions Risks, (and why it may be time to become best friends with your “Sanctions Practice” law partner), Live presentation at ABA Tax Section’s Annual May Meeting in Wash., D.C.
Faculty speaker, Lawyers in the Crosshairs: Ethics & Evolving Transparency Issues Facing Attorneys Advising Clients with Offshore Corporations and “beneficial ownership” issues, CLE provider: American Bar Association, Section of International Law, International Tax Committee, April 28, 2022
Lawyers in the Crosshairs: Ethics & Evolving Transparency Issues Facing Attorneys Advising Clients with Offshore Corporations and “beneficial ownership” issues, Live presentation at ABA International Law Section’s Annual Meeting, held in Wash., D.C.
Faculty speaker, Quelling the Climate Crisis: Designing TAX & TRADE Policies to End Carbon Pollution, CLE provider: American Bar Association, Section of International Law, International Tax Committee, April 26, 2022
Quelling the Climate Crisis: Designing TAX & TRADE Policies to End Carbon Pollution, Live presentation at ABA International Law Section’s Annual Meeting, held in Wash., D.C.
Faculty speaker, Foreign Subsidiary Selection: Check-the-Box Elections for Foreign Subs in light Recent Tax Law Changes, CLE/CPE provider: Strafford Publications, April 20, 2022
Moderator and Speaker, Cryptocurrency Developments, Including New Reporting Regimes in the United States and Abroad, Live panel presentation in New York, feature VP of Tax of Coinbase, December 7, 2021
Moderator and Speaker, Cryptocurrency Developments, Including New Reporting Regimes in the United States and Abroad, CLE provider: International Fiscal Association – USA Branch, December 7, 2021
Faculty speaker, GILTI High-Tax Exclusion Final Regulations: Tested Units, Controlled CFC Groups, and Retroactive Application, CLE/CPE provider: Strafford Publications, CLE & CPE accredited, November 16, 2021
Speaker at ABA Tax Section Fall Meeting 2021, Quelling the Climate Crisis: Designing TAX & TRADE Policies to End Carbon Pollution, CLE provider: ABA Tax Policy and Simplification Committee, September 24, 2021
Faculty speaker, Foreign Branches, QBUs, and Disregarded Entities: Foreign Tax Credits, Anti-Hybrid Rules, and Planning Strategies, CLE/CPE provider: Strafford Publications, Sept. 21, 2021
Moderator and Speaker, Cryptocurrency: Navigating Minefields in the Virtual Currency World, CLE/CPE provider: Strafford Publications, July 28, 2021
Moderator and Speaker, Back to the International Tax Policy Drawing Board: A Roundtable Discussion of the 2017 TCJA, Biden’s Tax Proposals, and Landmark OECD Tax Initiatives, CLE provider: American Bar Association Tax Section, May 2021
Back to the International Tax Policy Drawing Board: A Roundtable Discussion of the 2017 TCJA, Biden’s Tax Proposals, and Landmark OECD Tax Initiatives, Live panel presentation, part of the ABA Tax Section’s Annual May Meeting in Wash., D.C.
Faculty speaker, Section 754 Elections on Form 1065: Making Valid Elections, Seeking Relief For Missed or Invalid Elections, CLE/CPE provider: Strafford Publications, February 2, 2021
Faculty speaker, Maximizing the FDII Deduction for U.S. Exported Property and Services: Determining Foreign Use, Grouping Expenses, Optimizing the R&D Allocations, CLE provider: Strafford Publications, January 6, 2021
Faculty speaker, Tax Issues in Multinational M&A: Choice of Entity, Section 338(g) Election, GILTI vs. Subpart F, CLE provider: Strafford Publications, July 1, 2020
“IRC 338(g) Elections for Buyers of Controlled Foreign Corporation Stock in Wake of Major Changes“, Strafford Publications (nationwide webinar, Feb. 28, 2019)
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
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
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
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
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
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
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

Published Works

Articles

Pamela A. Fuller, International Tax – Year in Review 2017 – OECD BEPS Developments – Introduction, Developments 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
“Whither M&A in Japan?” New York Law Journal 10-11, April 2005

Bar Admissions

North Carolina, 1991
U.S. District Court Eastern District of North Carolina, 1993
U.S. District Court Middle District of North Carolina, 1993
U.S. District Court Western District of North Carolina, 1993
U.S. Tax Court, 1993
District of Columbia
Washington
U.S. Court of Appeals Federal Circuit
U.S. Court of International Trade

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Pamela A Fuller - New York, NY