Carina C. Federico
Areas of Focus
Overview
Clients trust Carina Federico to advise on wide-ranging, complex tax issues, including transfer pricing, investment tax credits, research and experimentation credits, and energy credits. Carina Federico handles tax disputes at all stages, including IRS audits, IRS Appeals, federal district court litigation, tax court litigation, and appellate court litigation 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.
Career & Education
- Department of Justice: Tax Division
Trial Attorney, 2011–2015 - The White House
Deputy Associate Counsel, 2015 - Maryland
Law Clerk, Honorable Ronald B. Rubin, Maryland Circuit Court for Montgomery County, 2010–2011 - U.S. Court of Federal Claims
Judicial Intern, Honorable Marian B. Horn, 2010
- Department of Justice: Tax Division
- Towson University, B.S., 2003
- American University Washington College of Law, J.D., summa cum laude, Order of the Coif; Publications Editor, Journal of Gender, Social Policy, and the Law, 2010
- California
- District of Columbia
- U.S. Tax Court
- U.S. Court of Federal Claims
- U.S. Court of Appeals for the Fifth Circuit
Professional Activities and Memberships
- American Bar Association, Section of Taxation, Tax Practice and Technology Committee, Vice-Chair, 2019–Present; Women in Tax Forum Vice-Chair, 2021–Present; Administrative Practice Committee, Vice-Chair of IRS Liaison Activities Sub-Committee, 2019–2021
- Federal Bar Association, Section on Taxation, Vice-Chair of Tax Practice and Procedure Roundtable, 2020–2021; Vice-Chair of Tax Law Conference, 2019–2020; Co-Chair of Women in Tax Law Group, 2016–2019
- Member of Editorial Board, Practical Tax Strategies, 2016–2018
Carina's Insights
Client Alert | 4 min read | 07.24.25
In April 2025, the IRS and the Department of Homeland Security (DHS) formalized a Memorandum of Understanding (MOU) enabling Immigration and Customs Enforcement (ICE) to create a system of information sharing between the agencies. Under the MOU, the IRS can share tax return information for non-tax criminal investigation purposes. More specifically, the MOU permits ICE to request sensitive tax information from the IRS for purposes of pursuing immigration related cases and deportations. Given the Trump administration’s focus on undocumented workers, the implications of the MOU likely will go even further as sharing this information will result in tax enforcement against employers of deported individuals.
Client Alert | 3 min read | 07.08.25
Trump Administration Announces Clean Energy Tax Credit Enforcement Ramp Up
Speaking Engagement | 06.26.25
"Substantiating And Defending Audits Of IRA Clean Energy Credits," NYU Tax Controversy Forum
Firm News | 11 min read | 06.05.25
Representative Matters
- Advising clients in the energy and manufacturing sectors regarding the Inflation Reduction Act clean energy tax credits.
- Advising clients regarding the transferability and direct pay provisions in the Inflation Reduction Act.
- Representing a retail and health care company in a tax controversy matter regarding the domestic production activities deduction.
- Successfully settled a research credit case in U.S. Tax Court for a global supplier of automotive parts regarding whether tooling expenses should be treated as qualified research expenses.
- Representing public health care companies in federal district court litigation in a tax refund action concerning the domestic production activities deduction.
- Represented public oil and gas company on environmental tax credits focused on carbon capture and sequestration (Section 45Q).
- Represented multinational retail company in transfer pricing dispute before U.S. Competent Authority.
- Successfully represented large hospitality company in five-day-long arbitration over distributions made under hotel management agreements.
- Served as counsel to a principal in a contract manufacturing arrangement in a tax refund action concerning the domestic production activities deduction.
- 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 $600 million 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.
Carina's Insights
Client Alert | 4 min read | 07.24.25
In April 2025, the IRS and the Department of Homeland Security (DHS) formalized a Memorandum of Understanding (MOU) enabling Immigration and Customs Enforcement (ICE) to create a system of information sharing between the agencies. Under the MOU, the IRS can share tax return information for non-tax criminal investigation purposes. More specifically, the MOU permits ICE to request sensitive tax information from the IRS for purposes of pursuing immigration related cases and deportations. Given the Trump administration’s focus on undocumented workers, the implications of the MOU likely will go even further as sharing this information will result in tax enforcement against employers of deported individuals.
Client Alert | 3 min read | 07.08.25
Trump Administration Announces Clean Energy Tax Credit Enforcement Ramp Up
Speaking Engagement | 06.26.25
"Substantiating And Defending Audits Of IRA Clean Energy Credits," NYU Tax Controversy Forum
Firm News | 11 min read | 06.05.25
Recognition
- Chambers USA: Tax, District of Columbia, 2023–2025; Chambers USA: Tax Controversy, (Up and Coming) – Nationwide, 2024–2025
- Best Lawyers in America: Ones to Watch: Washington, DC Litigation and Controversy-Tax, Tax Law, 2023
- American Bar Association, Section of Taxation: John S. Nolan Fellowship, 2020, 2021
Carina's Insights
Client Alert | 4 min read | 07.24.25
In April 2025, the IRS and the Department of Homeland Security (DHS) formalized a Memorandum of Understanding (MOU) enabling Immigration and Customs Enforcement (ICE) to create a system of information sharing between the agencies. Under the MOU, the IRS can share tax return information for non-tax criminal investigation purposes. More specifically, the MOU permits ICE to request sensitive tax information from the IRS for purposes of pursuing immigration related cases and deportations. Given the Trump administration’s focus on undocumented workers, the implications of the MOU likely will go even further as sharing this information will result in tax enforcement against employers of deported individuals.
Client Alert | 3 min read | 07.08.25
Trump Administration Announces Clean Energy Tax Credit Enforcement Ramp Up
Speaking Engagement | 06.26.25
"Substantiating And Defending Audits Of IRA Clean Energy Credits," NYU Tax Controversy Forum
Firm News | 11 min read | 06.05.25
Insights
- |
09.26.23
The Journal of Federal Agency Action
Can Pharma Firms Deduct Fees In Hatch-Waxman Suits?
|07.18.23
Life Sciences Intellectual Property Review
TEI Seattle
|12.10.24
“IRA Clean Energy Credits and Anticipated Enforcement,” 2024 NYU Tax Controversy Forum
|06.27.24
- |
05.24.24
Thomson Reuters Practical Law
Carina's Insights
Client Alert | 4 min read | 07.24.25
In April 2025, the IRS and the Department of Homeland Security (DHS) formalized a Memorandum of Understanding (MOU) enabling Immigration and Customs Enforcement (ICE) to create a system of information sharing between the agencies. Under the MOU, the IRS can share tax return information for non-tax criminal investigation purposes. More specifically, the MOU permits ICE to request sensitive tax information from the IRS for purposes of pursuing immigration related cases and deportations. Given the Trump administration’s focus on undocumented workers, the implications of the MOU likely will go even further as sharing this information will result in tax enforcement against employers of deported individuals.
Client Alert | 3 min read | 07.08.25
Trump Administration Announces Clean Energy Tax Credit Enforcement Ramp Up
Speaking Engagement | 06.26.25
"Substantiating And Defending Audits Of IRA Clean Energy Credits," NYU Tax Controversy Forum
Firm News | 11 min read | 06.05.25