Pamela A. Fuller

Pamela Ann Fuller
Pamela A. Fuller
International, M & A, Tax
District of Columbia

Pamela advises a wide range of clients–including private and public companies; joint ventures; “start-ups”; private equity and hedge funds; venture capital funds; real estate funds and trusts; family offices; C-Suite executives; and government entities–on transactional, investment, growth, and supply-chain strategies to achieve optimal tax and business results. As a seasoned practitioner and tax technician, Ms. Fuller is accustomed to handling nuanced matters involving highly technical questions of law, policy, and procedure at the federal, state, and international levels. She provides sophisticated and often innovative global tax planning services across many industry sectors, including software & emerging digital technologies, financial services, real estate, healthcare, pharmaceutical, construction & engineering, infrastructure, oil & energy, fashion, and on-line retail.


Pamela is also an effective taxpayer advocate with nearly two decades of experience resolving U.S. federal, state, and foreign tax controversies.  Some of the tax disputes Pamela has handled have involved novel questions of law. She also has significant experience with complex transfer pricing issues–skills she first acquired when serving as Attorney Advisor to the Chief Judge of the United States Tax Court in Washington D.C. for three consecutive two-year terms at the very start of her legal career.


Pamela often speaks on international tax developments and strategies at various tax law conferences, including those sponsored by the American Bar and the New York State Bar Associations.  She writes and publishes in the international tax and securities law areas, and serves as a substantive law review editor of the renowned U.S. International Tax Portfolio series–a leading, authoritative resource for tax professionals, which has been published by BNA (and now Bloomberg) for almost 60 years.


Prior to becoming an attorney, Pamela was a business reporter and all-news radio anchor for a highly regarded NBC News affiliate in her hometown of Seattle, Washington, covering geo-political and international business developments, including the emergence and growth of major multinational companies like Microsoft, Starbucks, McCaw Communications, Hewlett-Packard, Nintendo, and Boeing.



Recent Speaking Engagements:
• June 19, 2018: Faculty/Panelist, “Check-the Box Elections for Foreign Subsidiaries: Achieving Optimal Tax Treatment through Entity Selection in light of the 2017 US Tax Act,” Strafford Publications (nationwide webinar on cross-border tax planning).
• June 11, 2018: Fuller is chairing and speaking on an in-person international panel discussing several hot topics in international tax, including the impact of the 2017 US Tax Act on cross-border tax planning and structuring. Panel is part of “Global Law Week”—sponsored by New York State Bar Association in Midtown Manhattan, June 11-15, 2018.
• May 30, 2018: Faculty/Panelist, “Check-the Box Elections for Foreign Subsidiaries: Achieving Optimal Tax Treatment through Entity Selection in light of the 2017 US Tax Act,” Strafford Publications (nationwide webinar on cross-border tax planning).
• May 23, 2018: Speaker/Panelist, “Inbound Tax Issues in light of the 2017 U.S. Tax Act, American Bar Association, Section of International Law.
• Faculty/Panelist, “Section 754 Elections on Form 1065: Making Valid Elections – Seeking Relief for Missed or Invalid Elections,” Strafford Publications (nationwide webinar on partnership taxation), Oct. 11, 2017 (still available as on-line webcast).
• Speaker/Panelist, “International Tax Issues in Mergers & Acquisition,” ABA International Law Section – Spring Mtg., Wash., D.C., April 26, 2017.
• Faculty/Panelist, “Check-the Box Elections for Foreign Subsidiaries: Achieving Optimal Tax Treatment through Entity Selection“, Strafford Publications (nationwide webinar on cross-border tax planning), Oct. 20, 2016 (still available as on-line webcast).
• Faculty/Panelist, “Foreign Outbound Transactions Planning: Navigating Deferral under Subpart F and the new IRC 7874, § 367, and § 385 Regulations,” Strafford Publications (nationwide webinar on international tax planning), Aug. 16, 2016 (still available as on-line webcast).
• Speaker/Panelist, “Key Legal Issues in U.S. Mergers & Acquisitions for European Lawyers,” ABA International Law Section – Europe Forum, Rome, Italy, May 28-29, 2016.


Representative Publications:
• Pamela A. Fuller, International Tax – Year in Review 2017 – OECD BEPS Developments – Introduction, Developments in China, Developments in Japan, __ Intern’l Lawyer __ (2018), ABA Section of Int’l Law & Southern Methodist University School of Law (forthcoming).
• Pamela A. Fuller (Session Rapporteur), “Structuring the Deal in Light of BEPS (Base Erosion & Profit Shifting Initiatives),” Session Report on presentation by Int’l Bar Assoc.- Corporate/M&A Law Committee and Taxes Committee, Annual Congress of Int’l Bar Assoc., Tokyo, Japan, IBA M&A Committee, Oct. 10, 2015.
• Pamela A. Fuller (Session Rapporteur): “Debt-Equity Characterization Issues,” Session Report on Taxes Committee Presentation, 3rd Annual IBA/Capital Markets – International Tax Conference, London, England, Oct. 2014.
• Pamela A. Fuller (Session Rapporteur): “The Use of Partnerships in International Joint Ventures and Other Investments,” (detailed 4-part commentary and report on tax planning with hybrid entities and instruments in cross-border context), Taxes Committee, International Bar Association, Annual Congress, Dubai, 2012.
• Pamela A. Fuller, The Japan-U.S. Income Tax Treaty: Signaling New Norms, Inspiring Reforms, or Just Tweaking Anachronisms in International Tax Policy?, 40:4 Intern’l Lawyer 773-908 (2006), published by American Bar Assoc. & Southern Methodist University, available at
• Pamela A. Fuller, “Whither M&A in Japan?” New York Law Journal 10-11, April 2005 (Full-page article details Japan’s adoption of Anglo-American styled corporate tax and M&A rules that, at least initially, appeared to incorporate much of Delaware’s hostile takeover jurisprudence. Article also discusses the historic, cultural, and corporate governance reasons behind Japan’s decades-old reluctance to join other industrialized countries in adopting modern cross-border tax and M&A rules).


• B.A., University of Washington, Seattle, Wash.
• J.D., Seattle University School of Law
• LL.M. (Taxation), New York University School of Law
• Post-LL.M. Studies (Intern’l & Comparative Law), New York University School of Law

Admitted to Practice

• District of Columbia
• Washington State
• North Carolina
• U.S. Tax Court
• U.S. Court of International Trade
• U.S. Court of Appeals for the Federal Circuit


• American Bar Association (Tax, International Law, Business Law Sections)
• New York State Bar Association (Tax, Int’l Law, Trusts & Estates, Business Law Sections)
• District of Columbia Bar Association (Tax and International Law Communities)
• Bar Assoc. of City of New York (Task Force on Endangered Lawyers; Asia-Pacific Committee)
• International Fiscal Association (U.S.A. Branch)
• International Bar Association (Taxes Committee, Private Tax Clients Committee, Europe Forum)
• Japan Society of New York
• Center for Japanese Economy and Business (CJEB), Columbia University
• Center for Japanese Legal Studies, Columbia University School of Law
• Center for Chinese Legal Studies, Columbia University School of Law
• Yale Club of New York City (2006)
• Kappa Alpha Theta (lifetime member, officer)
• Sigma Delta Chi (Society of Professional Journalists)
• Women in Communications

Government Experience

• Attorney Advisor, The Honorable Lapsley W. Hamblen, Jr., Chief Judge of U.S. Tax Court, United States Tax Court, Washington, D.C., 1990 – 1995.
• Attorney Advisor, The Honorable William M. Drennen, Former Chief Judge of U.S. Tax Court, United States Tax Court, Washington, D.C., 1991-1993.
• Judicial Law Clerk, Washington State Superior Court (highest trial court), Bremerton, Wash., 1989.
• Law Clerk, Seattle-King County Public Defenders’ Office, 1988.