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Caroline C. Setliffe

Partner

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Languages: Arabic, Armenian, French

Caroline represents multinational corporations in complex domestic and foreign tax controversies. 

Caroline provides a special focus on treaty considerations and transfer pricing issues taking into account the latest OECD developments. Clients and peers highly regard her for her ability to navigate negotiations and resolutions of sensitive, high-stakes disputes that have domestic and international implications. 

Early in her career, Caroline worked at the United States Tax Court and the Joint Committee on Taxation, providing her a solid litigation foundation and a view into how complex tax provisions are structured. She brings a keen understanding of the tax litigation process to every stage of a tax controversy, and emphasizes early litigation preparedness as the key to avoiding the need for litigation. In this regard, Caroline counsels clients at all stages of the tax controversy process, including pre-audit, audit, appeals, and Competent Authority. When litigation is necessary, however, she embraces trial planning through strategic thinking, excellent witness preparation, and strong substantive and procedural knowledge. On international tax controversies and litigation, she draws on her diverse cultural background and proficiency with multiple languages in her interactions and collaborations with foreign advisers to provide innovative, resolution-oriented foreign strategies with a view toward domestic consequences of actions taken in foreign jurisdictions.

Prior to joining Eversheds Sutherland, Caroline worked at large international law firms, where she represented clients in all phases of federal tax controversy matters and litigation. Caroline also served as attorney-advisor to Robert N. Armen, Jr., of the United States Tax Court and served as a Legislation Counsel to the Joint Committee on Taxation with a special focus on excise taxes.

  • Supply Chain Panel, December 15, 2023, 34th Annual Institute on Current Issues in International Taxation
  • Effective Collaboration with Legal, Regulatory and Business Teams in Setting the Global Operating Structure Amid Increasing Regulation and Compliance, June 21, 2023
  • Navigating International Tax Controversies in a Measured Way: Special Focus on Transfer Pricing Considerations, April 19, 2023
  • Global views on value-added tax (VAT) treatment of physical goods, March 28, 2023
  • Practical impact of anti-avoidance measures, March 8, 2023
  • The Interplay Between OECD BEPS 2.0 (Pillar 2) and US Tax Law; the New US Corporate AMT and GILTI, March 2, 2023, 6th Annual Women in Tax Forum
  • Value Added Tax (VAT), December 6, 2022
  • International Tax Controversy: Navigating the Complex International Controversy Web, November 16, 2022, Philly Tax Day
  • SALT and Federal Tax Litigation Update, November 16, 2022, Philly Tax Day
  • Planning Ahead: International Dispute Resolution, September 13, 2022
  • Strategies for transfer pricing risk management, compliance and mutual agreement procedures, July 27, 2022)
  • Managing and resolving International Tax Controversy Issues, May 24, 2022, ITR Women in Tax Forum
  • Significant Tax Controversy Updates, February 7, 2022, Atlanta Tax Forum
  • Significant Tax Controversy Updates of 2021, December 2, 2021, Philly Tax Days webcast series
  • Navigating Privilege and Ethics Obligations, December 2, 2021, Philly Tax Days webcast series
  • Navigating Privilege and Ethics Obligations, September 21, 2021, TEI Wisconsin – Ethics Session
  • Federal and State Controversy Update, April 17, 2019, TEI Seattle Chapter Meeting
  • Recognized by The Legal 500 United States in the areas of international tax (2021-2023) and US taxes: contentious (2020)
  • Named to the “Ones to Watch” list by The Best Lawyers in America in the area of tax law (2021-2024)
  • Member, J. Edgar Murdock (Tax Court), American Inns of Court
  • Member, American Bar Association
  • Member, Federal Bar Association
  • District of Columbia
  • Maryland
  • New Jersey
  • Virginia
  • U.S. District Court for the District of Puerto Rico
  • U.S. Court of Federal Claims
  • U.S. Tax Court
  • U.S. Supreme Court
  • LL.M., Georgetown University Law Center
  • J.D., Syracuse University College of Law
  • B.A., cum laude, Virginia Polytechnic Institute and State University
Caroline Setliffe

Partner

Caroline Setliffe

Partner

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