Linda E. Carlisle's practice focuses on advising corporations and flow-through entities, such as partnerships, limited liability companies and Subchapter S corporations on both domestic and international tax issues. In addition, Ms. Carlisle assists clients with employee stock ownership plans (ESOPs), intercompany pricing issues, financial derivative product issues, and legislative, regulatory and administrative tax matters. Ms. Carlisle is also a leading authority on the taxation of publicly traded partnerships.
Ms. Carlisle advises U.S. and non-U.S. companies on reorganization and acquisition and sale transactions and successfully obtains private letter rulings from the Internal Revenue Service (IRS) when necessary. She also assists clients in devising and defending their transfer pricing. Clients quoted by Chambers have said that Ms. Carlisle is "a great technical resource. She renders her service in a very efficient way, and is very prompt and responsive. She does really good quality work and has excellent relationships with the IRS and Treasury."
She has testified before the U.S. Congress and the IRS, obtained numerous IRS private letter rulings, achieved favorable administrative and judicial resolutions of tax adjustments proposed by the IRS, obtained refunds of overpaid U.S. tax and successfully contested proposed foreign tax adjustments through tax treaty provisions ("competent authority" proceedings). More >
- Tax Counsel to a U.S.-based multinational corporation in structuring corporate reorganization and obtaining IRS ruling for transaction.
- Tax Counsel to a U.S.-based multinational corporation in analyzing and resolving ESOP issues.
- Tax Counsel to two trade associations representing their interests before Congress and the Administration.
- Tax Counsel to U.S. and foreign-based multinational corporations on transfer pricing issues.
- Advises foreign governments on possible legislative changes.
- Special Assistant to the Assistant Secretary for Tax Policy, Office of the Tax Legislative Counsel, U.S. Department of the Treasury, 1985 - 1987
- Attorney Advisor, Office of the Tax Legislative Counsel, U.S. Department of the Treasury, 1984 - 1985
Rankings and Recognition
- Chambers USA: Tax (District of Columbia), 2009 - 2016
- The Best Lawyers in America®: Tax Law, 2007 - 2017
- International Tax Review: Women in Tax Leaders, 2015 - 2016
- Legal 500: Government: Government Relations, 2015
- Legal 500: Tax: Domestic Tax, 2007, 2010 - 2011, 2013 - 2015
- Legal 500: Tax: International Tax, 2014
- Tax Directors Handbook: U.S. Tax, 2008, 2011 - 2012, 2014
- Expert Guides: Women in Business Law: Tax, 2013 - 2014
- Expert Guides: Tax Advisers, 2014
Professional and Community Involvement
- Adjunct Professor, Georgetown University Law Center
- Former Chair, Tax Section, District of Columbia Bar
- Former Chair, Sections Council, District of Columbia Bar
- Fellow, American Bar Association
- Advisory Board Member, The American Law Institute
- Advisory Board Member, Journal of Taxation of Investments
- Advisory Board Member, Journal of Financial Products
- Co-Chair and Speaker, Practicing Law Institute (PLI), "Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations and Restructurings" Seminar
- Co-Chair and Speaker, PLI, "Basics of International Tax" Seminar
- Editorial Board, The Practical Tax Lawyer, The American Law Institute
- Member, Taxation and Financial Instruments Committee, New York Bar Association
- Member, Taxation and Financial Transactions Committee, American Bar Association
- Member, The Tax Coalition
- District of Columbia
- New York
- United States Tax Court
- United States District Court for the District of Columbia
- United States Court of Appeals for the District of Columbia Circuit
- LL.M., Georgetown University Law Center, 1984
- J.D., The Catholic University of America, 1980
- B.A., The University of Texas at Austin, 1970