Pamela A. Fuller, Esq.

Pamela A. Fuller, Esq.

ABOUT

Pamela A. Fuller is a corporate and international tax attorney, with over two decades of experience.  She advises a wide range of clients–including private and public companies, joint ventures, private equity and hedge funds, C-Suite executives, private U.S and foreign individual clients, and government entities–on transactional, investment, and supply-chain strategies to achieve optimal tax and business results.

Pamela provides sophisticated tax planning services across most industry sectors, including financial services, real estate development, healthcare, pharmaceutical, construction & engineering, infrastructure, oil & energy, retail, and myriad software and emerging digital technologies and services, including those related to crypto currency, tokenization, innovative blockchain applications and solutions, and all aspects of U.S. and foreign tax planning for digitized transactions and assets.

Pamela is also a seasoned taxpayer advocate, with years of experience resolving complex U.S. federal, state, and foreign tax controversies.  She is skilled at defending taxpayers before the U.S. Internal Revenue Service at the exam, audit, and administrative appeals levels.  If going to court is advantageous, Pamela provides effective and skillful tax counsel.

Pamela is Chair of the American Bar Association (ABA) Tax Section’s Tax Policy Committee, and also Co-Chair of the  International Tax Committee of the ABA’s International Law Section, with global membership.  She  frequently speaks at law conferences, and publishes papers on international tax topics in peer-reviewed law journals.  She serves on several steering committees and boards, including TaxLaw 360’s International Tax Advisory Board; the New York State Bar’s “Global Law Week”; and the International Fiscal Association’s prospective New York Congress.  Pamela is a founding member of the New York City Bar’s “Taskforce on the Independence of Lawyers and Judges” and a Fellow of both the American Bar Foundation and the American College of Tax Counsel.  In 2019, Pamela was recognized as one of 100 Influential Women in International Tax Law.

Pamela began her legal career at the U.S. Tax Court, serving three consecutive 2-year terms as an Attorney Advisor to the U.S. Tax Court’s Chief Judge, handling large “tax shelter” cases and transfer pricing disputes, amongst other issues.  Pamela holds an LL.M. in Tax Law from New York University School of Law, where she served as Graduate Editor of  NYU’s international law review, and completed post-LL.M. studies in international business and comparative securities law; a J.D. from Seattle University; and a B.A. from the University of Washington.  Pamela is admitted to practice law in several U.S. state jurisdictions and multiple federal courts, including the U.S. Tax Court.

Prior to becoming an attorney, Pamela worked as a business news reporter and anchor for a highly regarded NBC News affiliate in Seattle, covering international and emerging tech businesses, and geo-political developments.  In this capacity, Pamela had the opportunity to conduct in-depth interviews with the founders and executives of some of the world’s most innovative and successful companies.

SELECTED TRANSACTIONS

STO for a Major Foreign Digital Exchange and Wallet Service

Represented a client in tokenizing a part of equity in a foreign digital currency exchange and digital wallet by offering tokenized preferred shares through a U.S. SPV (Delaware corporation).

STO for Developing Renewable Energy Farms + Data Centers

Represented a non-US issuer in structuring a security token offering (STO) for developing a digital currency operation in the US and abroad

STO for Digital Currency Exchange and E-commerce Platform

Represented a FinTech company developing a digital currency exchange and e-commerce platform with structuring a security token offering (STO) featuring multiple types of security tokens, with and without voting rights and dividend distributions

STO for Blockchain-based Marine Navigation Network

Represented blockchain-based marine navigation service with AI capabilities in structuring a security token offering (STO) in the US

STO for Digital Healthcare Platform

Represented a non-US issuer in connection with launching a security token offering (STO) for developing and operating digital healthcare platform

STO for B2B / B2C Blockchain Freelance Platform

Represented B2B / B2C blockchain freelance platform in the process of raising capital through Regulation D and S offerings to U.S. and non-U.S. investors, including review and analysis of the white paper and the project, preparation of the private placement memorandum (PPM), subscription agreements, guidance regarding the process of investor accreditation as well as AML/KYC checks, and filing Form D with the SEC.

STO for Blockchain-Based Gaming Platform

Represented a non-US issuer in connection with launching a $30M security token offering (STO) in the US for developing a blockchain-based gaming platform

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