Photograph of Carina C. Federico

Government Experience

  • Department of Justice: Tax Division—Trial Attorney (2011-2015)
  • The White House—Deputy Associate Counsel (2015)
  • Maryland—Law Clerk, Hon. Ronald B. Rubin, Maryland Circuit Court for Montgomery County (2010-2011)
  • U.S. Court of Federal Claims—Judicial Intern, Hon. Marian B. Horn (2010)

Education

  • Towson University, B.S. (2003)
  • American University Washington College of Law, J.D. (2010) summa cum laude, Order of the Coif; Publications Editor, Journal of Gender, Social Policy, and the Law

Admissions

  • California
  • District of Columbia

Carina C. Federico

Counsel
Washington, D.C.
cfederico@crowell.com
Phone: +1 202.654.6712
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595

Carina Federico is a counsel 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, 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
  • American Bar Association, Section of Taxation, Administrative Practice Committee, Vice-Chair of IRS Liaison Activities Sub-Committee
  • Women’s Bar Association
  • American Bar Association, Section of Taxation, Tax Practice Management Committee, Vice-Chair

Recognition

  • John S. Nolan Fellowship (2020-2021), American Bar Association, Section of Taxation

Speeches & Presentations

  • "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 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 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


Client Alerts & Newsletters


Media Mentions


Firm News & Announcements

Jan.04.2021 Crowell & Moring Elects Nine New Partners and Promotes 18 to Counsel Positions
May.18.2020 Crowell & Moring's Carina Federico Named ABA Tax Section Nolan Fellow