Ms. Poole brings 35 years of experience as a tax lawyer to Potomac Law. Over the course of her career, she has regularly advised on complex partnership, corporate, international tax and tax-exempt issues. She has successfully handled numerous tax controversies with the IRS and state and foreign tax authorities, and regularly deals with the IRS on behalf of clients. Ms. Poole has extensive experience with cross border transactions and regularly represents foreign companies investing or operating in the United States, advising on treaty provisions, U.S. withholding taxes and the tax consequences arising from being engaged in a trade or business in the United States. She has advised on a wide range of topics, including the purchase and sale of businesses, tax-free acquisitive and internal reorganizations, including in the specialized areas of real estate investment trusts and UPREIT structures, tax disclosure and tax opinions for private and public securities offerings, initial stage solar energy projects, and crypto currency initial offerings and other crypto transactions.
As Tax General Counsel of a Fortune 100 company, Ms. Poole was responsible for the tax implications of all worldwide activities, including worldwide tax planning, tax compliance and controversies with tax authorities, evaluating business structure options, assessing the risk of tax positions taken and the soundness of the financial reporting of tax positions. She also led the corporate and tax work on a $2 billion European corporate restructuring involving eight tax jurisdictions.
At prior AmLaw 100 law firms, Ms. Poole advised global investors with respect to structuring cross border transactions into the United States and, for non-U.S. investments, Ms. Poole led and coordinated the efforts of tax advisors in the relevant jurisdictions. She also represented some of the largest residential, retail and office REITS in the country.
More recently, Ms. Poole has focused her wide-ranging experience and knowledge on assisting small and mid-size businesses. Her clients value not only her technical skills, but also her keen judgement in assessing tax risk, her ability to quickly get to the heart of complex issues and her attention to thinking beyond the task at hand to anticipate and address problems before they surface.
Ms. Poole has obtained section 501(c)(3) status for several nonprofits and has earned numerous pro bono awards.
- Led a $2 billion tax restructuring of a European holding company structure involving eight tax jurisdictions
- Developed structure for direct investment in India which minimized Indian tax risk
- Developed legal and factual arguments in connection with an excise tax controversy at IRS Appeals level, resulting in the IRS dropping the claim entirely and the client paying no settlement amount
- Developed legal arguments in connection with a claim by the Kuwait tax authority against a non-resident client for income taxes due, resulting in the Kuwait tax authority dropping the claim
- Developed legal arguments in connection with a California tax authority challenge to the tax treatment of a corporate reorganization, resulting in the California tax authority dropping the claim entirely and the client paying no settlement amount
- Successfully challenged a state taxing authority's claim for Use Tax on the purchase of an aircraft.
Publications and Speeches
- "Foreign Investment in Real Property Tax Act," Author of a chapter in the Manual of Foreign Investment in the United States (West, a Thompson business)
- Duke Center for International Development's Program on Tax Policy, Revenue Estimation, and Legal Environment of Taxation, Speaker on tax issues of concern to foreign investors, Presented to representatives of the Nigeria Federal Inland Revenue Service, Washington D.C., 2013
PRO BONO AND COMMUNITY INVOLVEMENT
- African Arts Foundation, Director
- Nollywood Foundation, Director and Treasurer
- BuildingBlocks International, Director
- Luxol Blue, Director
News, Events & Insights
Duke University School of Law, J.D.
- Graduated with Honors
- Articles Editor, Law and Contemporary Problems
University of Michigan, A.B.
- Graduated with Distinction
- General Dynamics, Director and Tax General Counsel
- King & Spalding LLP, Tax Counsel, Member of the Hiring and Prob Bono Committees
- Hogan & Hartson LLP, Partner, Chair, Business and Finance Training Committee, Member of the Partner Review Committee
- District of Columbia