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Carina C. Federico

Partner | She/Her/Hers
Partner | She/Her/Hers
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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.

Carina counsels clients on tax policy matters, by engaging regularly with key stakeholders at the Department of Treasury and Internal Revenue Service on behalf of clients seeking regulatory changes or clarity in existing regulations, and submitting comments on proposed regulations and other guidance. Carina also advises taxpayers interested in claiming tax credits and incentives, including the energy tax credits under the Inflation Reduction Act.

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.

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
      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

    • 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
    • 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
    • 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

    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

What’s Old is New Again: the Expansion of Sharing Tax Information and the Effect on Employment and Immigration Cases

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....

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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

What’s Old is New Again: the Expansion of Sharing Tax Information and the Effect on Employment and Immigration Cases

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....

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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

What’s Old is New Again: the Expansion of Sharing Tax Information and the Effect on Employment and Immigration Cases

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....

View All Insights

Insights

Client Alert | 4 min read | 07.24.25

What’s Old is New Again: the Expansion of Sharing Tax Information and the Effect on Employment and Immigration Cases

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

Crowell Attains Leading Rankings in Chambers USA 2025

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Practices

Carina's Insights

Client Alert | 4 min read | 07.24.25

What’s Old is New Again: the Expansion of Sharing Tax Information and the Effect on Employment and Immigration Cases

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....

View All Insights