Caroline C. Setliffe

With a deep understanding of both U.S. tax law and international tax principles, she provides integrated, strategic counsel that addresses the multifaceted challenges facing global enterprises operating in an increasingly complex regulatory environment.

Widely recognized for her formidable advocacy and strategic acumen, Caroline has established a distinguished reputation for navigating complex, high-stakes tax disputes. She combines incisive analytical skills with unwavering determination and a solutions-oriented mindset to consistently achieve superior outcomes for her clients in the most challenging matters.

In domestic tax controversies, Caroline brings comprehensive knowledge of the tax litigation process to every stage of a dispute. She emphasizes early litigation preparedness as essential to achieving favorable resolutions and avoiding protracted litigation. Caroline advises clients throughout the entire tax controversy lifecycle, including pre-audit planning, IRS examinations, administrative appeals, and Competent Authority proceedings. When litigation becomes necessary, she employs rigorous trial preparation strategies, including meticulous witness preparation, sophisticated legal analysis, and deep substantive and procedural expertise to position clients for success.

In international and foreign tax controversies, Caroline leverages her diverse cultural background and multilingual proficiency to facilitate seamless collaboration with foreign advisers and tax authorities. She develops innovative, resolution-oriented strategies for cross-border tax issues while maintaining a comprehensive view of the domestic implications of actions taken in foreign jurisdictions, ensuring coordinated and effective representation across multiple tax regimes.