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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 Releases Guidance Regarding Section 45Q Carbon Capture and Sequestration Tax Credit," Tax Alert (July 6, 2021). Contacts: David B. Blair, David J. Fischer, Carina C. Federico, Eric Homsi
Client Alert / Newsletter
"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: S. Starling Marshall, Carina C. Federico
Client Alert / Newsletter
"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
Client Alert / Newsletter
"IRS Continues to Boost Enforcement Efforts with New Promotor Investigation Office," Administrative Law Alert (April 26, 2021). Contacts: S. Starling Marshall, Glen G. McGorty, Carina C. Federico, Lisa Nicole Umans
Client Alert / Newsletter
More Prosecutions Likely In IRS Scheme Promoter Crackdown Law360 (April 23, 2021)
Media Mentions
"IRS Civil and Criminal Compliance and Enforcement Update," ABA Administrative Practice Roundtable (April 21, 2021). Presenter: Carina Federico.
Speech/Presentation
"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: James G. Flood, S. Starling Marshall, Carina C. Federico, W. Scott Douglas, Tim Shadyac
Client Alert / Newsletter
"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.
Publication
"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.
Speech/Presentation
"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: S. Starling Marshall, Carina C. Federico
Client Alert / Newsletter

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Crowell & Moring LLP is an international law firm with offices in the United States, Europe, MENA, and Asia that represents clients in litigation and arbitration, regulatory and policy, and transactional and corporate matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation and government-facing matters, as well as its ongoing commitment to pro bono service and diversity, equity, and inclusion.

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