Caroline R. Reaves

Caroline R. Reaves' practice covers a broad range of federal income tax matters, with a focus on cross-border transactional issues and business activities. She has represented both domestic and international corporations, partnerships, individuals, and S corporations in the energy, technology, consumer product, healthcare, and industrial sectors. She has counseled clients on obtaining favorable private letter rulings (PLRs), advance pricing agreements (APAs), and competent authority agreements, as well as resolving federal income tax controversies at the audit level and at Internal Revenue Service (IRS) Appeals. 

Her advisory work includes issues involving corporate reorganizations, debt characterization, foreign tax credits, accounting issues, transfer pricing, the corporate alternative minimum tax (CAMT), and the international tax provisions of the Tax Cuts and Jobs Act of 2017 (TCJA), such as foreign-derived intangible income (FDII), global intangible low-taxed income (GILTI), and the base erosion and anti-abuse tax (BEAT). In recognition of her domestic and cross-border work, Caroline was named "One to Watch" in both Litigation & Controversy and Tax Law by The Best Lawyers in America, 2024.

Caroline is a frequent speaker at American Bar Association (ABA), International Fiscal Association, Federal Bar Association, and Tax Executives Institute (TEI) events and presents on a broad range of topics, including transfer pricing, Pillar 1 and Pillar 2, and common-law doctrines. She has published articles on international tax issues in Bloomberg Tax, Tax Notes, and Law360 Tax Authority.