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Carina C. Federico

Counsel

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.

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

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

View More

"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.
Speech/Presentation
"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.
Speech/Presentation
"Treasury and the IRS Release Final Regulations Regarding Section 45Q Carbon Capture and Sequestration Tax Credit," Tax Alert (January 8, 2021). Contacts: David B. Blair, David J. Fischer, Carina C. Federico
Client Alert / Newsletter
Crowell & Moring Elects Nine New Partners and Promotes 18 to Counsel Positions (Jan.04.2021)
Firm News / Announcement
"Congress Extends Section 45Q Beginning of Construction Date by Two Years in COVID-Relief Bill," Tax Alert (December 29, 2020). Contacts: David B. Blair, David J. Fischer, Carina C. Federico
Client Alert / Newsletter
"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.
Speech/Presentation
"Deputy Commissioner (LB&I) Flax Discuss Revised Procedures and Priorities During COVID-19 Pandemic," Tax Alert (November 4, 2020). Contacts: David B. Blair, Carina C. Federico
Client Alert / Newsletter
"Director of APMA Hughes Discusses Impact of COVID on APAs and MAP at Crowell & Moring Tax Seminar," Tax Alert (October 29, 2020). Contacts: David J. Fischer, Carina C. Federico
Client Alert / Newsletter
"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.
Speech/Presentation
"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.
Speech/Presentation

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Crowell & Moring LLP is an international law firm with approximately 550 lawyers representing clients in litigation and arbitration, regulatory and policy, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity, equity and inclusion. The firm has offices in Brussels, Doha, London, Los Angeles, New York, Orange County, San Francisco, Shanghai, and Washington, D.C.

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