Carina Federico is an associate in Crowell & Moring’s Tax Group and resident in the firm’s Washington, D.C. office.
Carina focuses her practice on federal tax controversy and tax litigation matters before the IRS and in trial and appellate courts across the United States. Her experience includes serving as first chair at trial, taking and defending depositions, briefing a wide range of tax issues, negotiating settlements, and representing clients in IRS Appeals conferences.
Before joining Crowell & Moring, Carina was an associate at an AmLaw 100 firm, where she represented clients in all stages of tax controversy and litigation. She was also seconded to Ernst & Young as a legal consultant to the general counsel’s office, where she advised EY engagement teams on tax controversy issues, including requests for penalty abatement and tax advice that could be given to audit clients.
Carina previously was a trial attorney at the U.S. Department of Justice, Tax Division, where she represented the IRS as lead counsel in civil actions, contested matters, and adversary proceedings before the U.S. District and Bankruptcy Courts, as well as in bankruptcy appeals before U.S. District Courts. At DOJ, Carina was awarded the Tax Division’s Outstanding Attorney Award in 2014 and a Special Commendation in 2013. She also served as deputy associate counsel for the White House, where she was the tax counsel on the vetting team for presidential nominations and appointments.
Representative Matters
- Served as counsel to a principal in a contract manufacturing arrangement in a tax refund action concerning the domestic production activities deduction under Section 199.
- Represented a financial services company before the IRS regarding the assessment of interest on a restitution amount.
- Represented an engineering firm before the IRS Office of Appeals regarding information reporting penalties.
- Served as independent investigation counsel on behalf of an external investigative committee of a multinational auto parts manufacturer looking into alleged accounting irregularities.
- Served as co-counsel on a $600M federal excise tax case involving fractional and whole aircraft management companies.
- Served as co-counsel in a summons enforcement case against a Fortune 500 company, which led to a favorable negotiated settlement.
Affiliations
Admitted to practice: California, District of Columbia, U.S. Tax Court
Professional Activities and Memberships
- Federal Bar Association, Section of Taxation, Co-Chair of Women in Tax Law group
- Member of Editorial Board, Practical Tax Strategies
- American Bar Association, Section of Taxation
- Women’s Bar Association
Speeches & Presentations
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"Managing Tax Controversies," Tax Executives Institute Cincinnati-Ohio Chapter, Columbus, OH
(February 26, 2019).
Presenters: David Fischer, Brad Anwyll, Teresa Abney, and Carina Federico.
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"Managing Tax Controversies," Tax Executives Institute Cincinnati-Ohio Chapter, Cincinnati, OH
(February 25, 2019).
Presenters: David Fischer, Brad Anwyll, Teresa Abney, and Carina Federico.
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"To Deduct or Not to Deduct: TCJA’s Impact on Government Settlements (IRC Sections 162(f) and 6050X)," ABA Administrative Practice Subcommittee on IRS Liaison Activities, Washington, D.C.
(February 20, 2019).
Presenters: Teresa Abney and Carina Federico.
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"Advice for the 21st Century Lawyer," 2019 Midyear ABA Tax Meeting, New Orleans, LA
(January 19, 2019).
Speaker: Carina C. Federico.
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"The IRS’s Use of AI and Big Data," ABA Webinar
(December 5, 2018).
Speaker: Carina C. Federico.
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"Talking Tax: How the IRS is using AI and Big Data," Bloomberg Talking Tax Podcast
(November 9, 2018).
Speaker: Carina C. Federico.
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"Managing Tax Controversies," Tax Executives Institute Philadelphia Chapter, Malvern, PA
(October 11, 2018).
Presenters: David Blair, Teresa Abney, and Carina Federico.
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"The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement," ABA Section of Taxation Fall Meeting
(October 5, 2018).
Speaker: Carina C. Federico.
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"Strategies for Cryptocurrency Disclosure and Audits," DC Bar’s Tax Audits and Litigation Lunch Series, Washington, D.C.
(June 20, 2018).
Speaker: Carina C. Federico.
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"Crypto-Currency: Disclosure & Audits, What to Do and How to Handle," ABA Section of Taxation May Meeting
(May 10, 2018).
Speaker: Carina C. Federico.
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"Fundamentals of Tax Litigation: Choice of Forum and Appealing Decisions," ABA Section of Taxation 4th Annual Young Tax Lawyers Symposium
(April 13, 2018).
Speaker: Carina C. Federico.
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"Talking Tax: Tax Cases at the Supreme Court," Bloomberg Talking Tax Podcast, Episode 61
(March 23, 2018).
Speaker: Carina C. Federico.
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"Defenses to Penalties," DC Bar’s Tax Audits and Litigation Series
(February 22, 2018).
Speaker: Carina C. Federico.
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"A Perspective on IRS Virtual Currency Enforcement Action," Blockchain, Accounting, Audit, and Tax Conference
(June 20, 2017).
Speaker: Carina C. Federico.
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"The IRS’s Use of John Doe Summons and the Coinbase Case," ABA Tax Administrative Practice Committee’s Subcommittee on IRS Liaison Activities
(March 15, 2017).
Speaker: Carina C. Federico.
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"IRS’s Final Regulations Regarding IRC Section 6103(n) Contractors," ABA Tax Administrative Practice Committee’s Subcommittee on IRS Liaison Activities
(July 20, 2016).
Speaker: Carina C. Federico.
Publications
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