Pamela Fuller
777 Third Avenue, 22nd Floor, New York, NY 10017
About Pamela Fuller
Practice Areas
- Tax
Education
- Seattle University School of Law, Seattle, WashingtonJ.D.
- Georgetown University Law Center, Washington, District of Columbia
- University of WashingtonB.A.
Languages
- English (Primary)
Classes and Seminars
- “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 [email protected] or project manager Alex Peters, [email protected].
- 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
- 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.
Qualifications
Bar Admissions
- District of Columbia
- North Carolina
- Washington
- U.S. Tax Court
- U.S. Court of Appeals Federal Circuit
- U.S. Court of International Trade
Past Positions
- 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
Articles
Published Works
- 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
- 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).
Office Info
Other Colleagues
- Business Law, Contracts
Nearby Lawyers
- Tax
- 0.3 mile away
The power of the lawyer is in the uncertainty of the law.