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.
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. 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.
Recognition
- 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
Affiliations
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
Representative Matters
- 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.
Speeches & Presentations
-
"Avoiding and Abating: A Discussion of Penalties and Defenses," Managing Tax Audits and Appeals Seminar 2022, Washington, D.C.
(October 6, 2022).
Speakers: Carina C. Federico and Samantha Skabelund.
-
"The Metaverse: Ethical Considerations for Tax Practitioners," 2022 ABA May Meeting
(May 13, 2022).
Speaker: Carina C. Federico.
-
"Remote Audit and Litigation Tools, Now and in the Future," Federal Bar Association - 2022 Tax Law Conference Webinar
(March 4, 2022).
Speaker: Carina C. Federico.
-
"Crowell & Moring and Detroit Tax Executives Institute Chapter 2022," IRS Administrative Affairs Webinar
(February 16, 2022).
Speakers: David B. Blair, S. Staring Marshall, Carina C. Federico.
-
"The Ethical Tax Professional in the Digital Age," 2022 Virtual ABA Midyear Tax Meeting, 2022.
(February 3, 2022).
Speakers: Carina Federico and Eleanor Moran McWaters.
-
Women Tax Lawyers in the COVID-19 era: Tips and Tricks for Building a Career, Maintaining Contacts, Achieving Balance, and More, 2022 Virtual ABA Midyear Tax Meeting, 2022.
(February 3, 2022).
Speaker: Carina Federico.
-
"LB&I Update: Emerging from the COVID-19 Pandemic," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021
(October 7, 2021).
Speakers: Nikole C. Flax, David B. Blair, and Carina C. Federico.
-
"Penalty Defense," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021
(October 5, 2021).
Speakers: S. Starling Marshall and Carina C. Federico.
-
"Audits: Selection, Examination, and Resolution," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021
(October 4, 2021).
Speakers: David B. Blair and Carina C. Federico.
-
"IRS Civil and Criminal Compliance and Enforcement Update," ABA Administrative Practice Roundtable
(April 21, 2021).
Presenter: Carina Federico.
-
"International Trade in 2021: What’s Ahead," Crowell & Moring Webinar
(February 17, 2021).
Presenters: Vassilis Akritidis, Caroline E. Brown, Michelle J. Linderman, Joshua Pond, Nicole Janigian Simonian, David R. Stepp, Robert Clifton Burns, Carina C. Federico, Jackson C. Pai, Nicole Sayegh Succar, Michael Bowen, Chandler S. Leonard, Brian McGrath, Nimrah Najeeb, and Joshua Boswell.
-
"IRS Appeals Procedures and Priorities during the COVID-19 Pandemic; Hot Topics in IRS Enforcement," 2021 TEI Cincinnati-Columbus Ohio Chapter IRS Administrative Affairs Meeting
(January 21, 2021).
Presenters: David J. Fischer, S. Starling Marshall, Carina C. Federico, and Eleanor Moran McWaters.
-
"LB&I Procedures and Priorities during the COVID-19 Pandemic," 2021 TEI Cincinnati-Columbus Ohio Chapter IRS Administrative Affairs Meeting
(January 19, 2021).
Presenters: David J. Fischer, S. Starling Marshall, Carina C. Federico, and Eleanor Moran McWaters.
-
"Transition 2021: Tax in 2021 and Beyond," Crowell & Moring Webinar
(December 10, 2020).
Presenters: David J. Fischer, S. Starling Marshall, Eric Homsi, and Carina C. Federico.
-
"Advance Pricing Agreements and Competent Authority Cases," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2020
(October 5, 2020).
Presenters: David J. Fischer and Carina Federico.
-
"LB&I’s Revised Procedures and Priorities During COVID-19 Pandemic," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2020
(October 5, 2020).
Presenters: David B. Blair and Carina Federico.
-
"Big Data and Artificial Intelligence in Audit Selection and Litigation," 2020 Virtual Fall ABA Tax Meeting
(October 1, 2020).
Moderator: Carina C. Federico.
-
"Use of Data Analytics in Criminal Tax Investigations," FBA Tax Law Conference, Washington, D.C.
(March 6, 2020).
Speaker: Carina C. Federico.
-
"Robots, Drones, Self-Driving Cars, A.I - Oh My!!!" 2019 Fall ABA Tax Meeting, San Francisco, CA
(October 4, 2019).
Speaker: Carina C. Federico.
-
"Specific Audits Issues: Penalties," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2019, Washington, D.C.
(September 12, 2019).
Presenters: Teresa Abney and Carina C. Federico.
-
"Audits Part One: Selection to Resolution," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2019, Washington, D.C.
(September 12, 2019).
Presenters: David B. Blair and Carina C. Federico.
-
"Panel Discussion with Executive Women from the IRS Office of Chief Counsel," FBA Section of Taxation, Women in Tax Law Group, Washington, D.C.
(August 1, 2019).
Moderator: Carina C. Federico.
-
"Technology & Social Media: Preparing New Tax Lawyers to Make Choices That Comply with Their Ethical Duties," ABA Section of Taxation 5th Annual Young Tax Lawyers Symposium, Washington, D.C.
(July 19, 2019).
Speaker: Carina C. Federico.
-
"How Artificial Intelligence and Other Technology Will Shape the Future of Tax Law," The D.C. Bar, Washington, D.C.
(April 24, 2019).
Panelist: Carina C. Federico.
-
"Managing Tax Controversies," Tax Executives Institute Cincinnati-Ohio Chapter, Columbus, OH
(February 26, 2019).
Presenters: David Fischer, Brad Anwyll, Teresa Abney, and Carina Federico.
-
"Managing Tax Controversies," Tax Executives Institute Cincinnati-Ohio Chapter, Cincinnati, OH
(February 25, 2019).
Presenters: David Fischer, Brad Anwyll, Teresa Abney, and Carina Federico.
-
"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.
-
"Advice for the 21st Century Lawyer," 2019 Midyear ABA Tax Meeting, New Orleans, LA
(January 19, 2019).
Speaker: Carina C. Federico.
-
"The IRS’s Use of AI and Big Data," ABA Webinar
(December 5, 2018).
Speaker: Carina C. Federico.
-
"Talking Tax: How the IRS is using AI and Big Data," Bloomberg Talking Tax Podcast
(November 9, 2018).
Speaker: Carina C. Federico.
-
"Managing Tax Controversies," Tax Executives Institute Philadelphia Chapter, Malvern, PA
(October 11, 2018).
Presenters: David Blair, Teresa Abney, and Carina Federico.
-
"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.
-
"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.
-
"Crypto-Currency: Disclosure & Audits, What to Do and How to Handle," ABA Section of Taxation May Meeting
(May 10, 2018).
Speaker: Carina C. Federico.
-
"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.
-
"Talking Tax: Tax Cases at the Supreme Court," Bloomberg Talking Tax Podcast, Episode 61
(March 23, 2018).
Speaker: Carina C. Federico.
-
"Defenses to Penalties," DC Bar’s Tax Audits and Litigation Series
(February 22, 2018).
Speaker: Carina C. Federico.
-
"A Perspective on IRS Virtual Currency Enforcement Action," Blockchain, Accounting, Audit, and Tax Conference
(June 20, 2017).
Speaker: Carina C. Federico.
-
"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.
-
"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
-
"Now Is The Time For Carbon Capture Projects," Bloomberg Tax Management Memorandum
(March 1, 2021).
Authors: David B. Blair, Larry F. Eisenstat, Carina C. Federico, and Tyler A. O'Connor.
-
"A Primer On The Tax Credit For Carbon Oxide Sequestration," Tax Notes
(July 27, 2020).
Authors: David B. Blair, David J. Fischer, Teresa Abney, and Carina C. Federico.
-
"INSIGHT: Impact Of Proposed IRS Regulations Under Section 45Q For Carbon Capture Credit," Bloomberg Law
(June 17, 2020).
Authors: David B. Blair, David J. Fischer, Teresa Abney, Carina C. Federico.
-
"INSIGHT: Automation And Data Analytics To Drive LB&I Audit Selection," Bloomberg Tax
(June 5, 2019).
Authors: Carina C. Federico, and David B.Blair
-
"Treasury Issues Policy Statement That May Be The Death Knell For 'Auer' Deference In Tax Cases And Zombie Notices," Bloomberg
(March 19, 2019).
Author: Carina C. Federico, David B. Blair, and Robert L. Willmore.
-
"Do IRS Computers Dream About Tax Cheats? Artificial Intelligence and Big Data in Tax Enforcement and Compliance," Journal of Tax Practice & Procedure, Wolters Kluwer
(February-March 2019).
Co-Author: Carina C. Federico.
-
"Improving Taxpayer Confidence in the IRS Office of Appeals," Law360
(April 30, 2018).
Author: Carina C. Federico.
-
"How Recent Actions Could Limit IRS Regulatory Authority," Law360
(May 2, 2017).
Co-Author: Carina C. Federico
Client Alerts & Newsletters
-
"Supreme Court Ruling Reduced Taxpayer’s Penalties by $2.67 Million,"
Tax Alert
(March 6, 2023).
Contacts: S. Starling Marshall, Carina C. Federico, Carlton Greene, Samantha Skabelund
-
"IRS Commissioner Nominee Daniel Werfel Testifies Before Senate Finance Committee,"
Tax Alert
(February 24, 2023).
Contacts: Carina C. Federico, S. Starling Marshall, James G. Flood
-
"Supreme Court Weighs Whether “Dual Purpose” Communications Are Privileged in In re Grand Jury,"
Tax Alert
(January 11, 2023).
Contacts: Carina C. Federico, S. Starling Marshall, Meshach Y. Rhoades, Rebecca Monck Ricigliano, Stephen J. McBrady, Peter Eyre
-
"Recent Tax Changes Affecting Research and Development Expenses and Credit Claims,"
Tax Alert
(March 9, 2022).
Contacts: S. Starling Marshall, Carina C. Federico
-
"IRS Releases Guidance Regarding Section 45Q Carbon Capture and Sequestration Tax Credit,"
Tax Alert
(July 6, 2021).
Contacts: Carina C. Federico, Eric Homsi
-
"Biden Administration Asks Congress for $80 Billion to Increase Enforcement Efforts and Announces Sweeping Legislative Agenda for Individual and Corporate Tax Enforcement,"
Administrative Law Alert
(May 11, 2021).
Contacts: Carina C. Federico, S. Starling Marshall
-
"Biden’s First 100 Days: Developments to Date and What Lies Ahead,"
Administrative Law Alert
(May 7, 2021).
Contacts: James G. Flood, Michael K. Atkinson, Tim Shadyac, Troy A. Barsky, Byron R. Brown, Caroline E. Brown, Robert A. Burton, Matthew Cohen, Kelly T. Currie, Jodi G. Daniel, W. Scott Douglas, Carina C. Federico, Paul Freeman, Thomas P. Gies, Alexis J. Gilman, Christine B. Hawes, Robert Holleyman, Stacie Heller, S. Starling Marshall, Shelley Su, Jeane A. Thomas, CIPP/E, Scott L. Winkelman, Tiffany Wynn, Kate Beale
-
"IRS Continues to Boost Enforcement Efforts with New Promotor Investigation Office,"
Administrative Law Alert
(April 26, 2021).
Contacts: Carina C. Federico, S. Starling Marshall, Glen G. McGorty, Lisa Nicole Umans
-
"Biden Administration Plans Tax Bill to Fund Economic Recovery, Appoints Lily Batchelder to Assistant Secretary for Tax Policy, U.S. Department of Treasury,"
Administrative Law Alert
(March 18, 2021).
Contacts: Carina C. Federico, James G. Flood, S. Starling Marshall, W. Scott Douglas, Tim Shadyac
-
"Biden Administration Appoints Four to Positions in Office of Tax Policy, Department of Treasury; IRS Announces Director of Taxpayer First Office,"
Administrative Law Alert
(February 8, 2021).
Contacts: Carina C. Federico, S. Starling Marshall
-
"Treasury and the IRS Release Final Regulations Regarding Section 45Q Carbon Capture and Sequestration Tax Credit,"
Tax Alert
(January 8, 2021).
Contact: Carina C. Federico
-
"Congress Extends Section 45Q Beginning of Construction Date by Two Years in COVID-Relief Bill,"
Tax Alert
(December 29, 2020).
Contact: Carina C. Federico
-
"Deputy Commissioner (LB&I) Flax Discuss Revised Procedures and Priorities During COVID-19 Pandemic,"
Tax Alert
(November 4, 2020).
Contact: Carina C. Federico
-
"Director of APMA Hughes Discusses Impact of COVID on APAs and MAP at Crowell & Moring Tax Seminar,"
Tax Alert
(October 29, 2020).
Contact: Carina C. Federico
-
"IRS Announces Proposed Regulations Under Section 45Q for Carbon Capture Credit,"
Tax Alert
(June 2, 2020).
Contact: Carina C. Federico
-
"IRS Releases First Cryptocurrency Tax Guidance Since 2014,"
Tax Alert
(October 10, 2019).
Contacts: Carina C. Federico, Charles C. Hwang, S. Starling Marshall
-
"Chief Counsel Desmond Discusses IRS Areas of Focus at Crowell & Moring Tax Seminar,"
Tax Alert
(September 26, 2019).
Contact: Carina C. Federico
-
"Deputy Commissioner (LB&I) Flax and Deputy Division Counsel (International) Askey Discuss Recent Developments at LB&I at Crowell & Moring Tax Seminar,"
Tax Alert
(September 26, 2019).
Contact: Carina C. Federico
-
"Taxpayer First Act Strengthens IRS's Procedural Requirements Before Initiating Third-Party Contacts,"
Tax Alert
(August 7, 2019).
Contact: Carina C. Federico
-
"Ninth Circuit Holds IRS Failed to Provide "Reasonable Notice" in Third-Party Summons Case,"
Tax Alert
(March 18, 2019).
Contact: Carina C. Federico
-
"Trump 2019: What To Expect in Tax Regulations,"
Regulatory Alert
(December 18, 2018).
Contact: Carina C. Federico
Press Coverage
-
Attorneys Unsurprised By Dismissal Of Tax Talks Privilege Case
February 16, 2023 — Tax Notes
-
IRS Modernization Plans Have Faced Setbacks, Report Finds
February 8, 2023 — Tax Notes
-
Tax Pros Must Be Cautious After Justices Boot Privilege Case
February 8, 2023 — Law360
-
‘Common Sense’ Flexibility Seen As Way To Ease Donation Disputes
January 25, 2023 — Tax Notes
-
Crowell & Moring Promotes Largest Partner Class In Its History
January 11, 2023 — Law360
-
IRS Could Boost Procurement With New Modernization Funding
January 1, 2023 — Tax Notes
-
A Look Ahead: Stakeholders Anticipate IRS Plan for New Funding
December 29, 2022 — Tax Notes
-
News Of IRS Hiring Blitz Universally Praised
March 14, 2022 — Tax Notes
-
More Prosecutions Likely In IRS Scheme Promoter Crackdown
April 23, 2021 — Law360
-
4 Takeaways From The Final IRS Carbon Capture Rules
January 21, 2021 — Law360
-
As IRS Ditches Contractor Experiment, Pitfalls May Persist
August 19, 2020 — Law360
-
News 'Doubling Down' On Big Data Upgrades IRS Fraud Investigations
December 5, 2018 — Bloomberg Tax
Firm News & Announcements