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Tax Counsel Carol Tello Authors BNA Tax Management Portfolio

October 9, 2002

WASHINGTON (October 9, 2002) – Carol P. Tello, tax counsel in Sutherland's Washington office, has authored a tax management portfolio for BNA's Foreign Income Series titled U.S. Withholding and Reporting Requirements for Payments of U.S. Source Income to Foreign Persons.

U.S. Withholding and Reporting Requirements for Payments of U.S. Source Income to Foreign Persons primarily focuses on U.S. withholding tax and Internal Revenue Service (IRS) reporting requirements related to investment income, including dividends and interest, that foreign investors receive from U.S. investments.  A major new tax concept explained in the portfolio is the "qualified intermediary."  Foreign financial institutions are now permitted to act as a U.S. withholding agent by assuming responsibility for the withholding and reporting of taxes on U.S. investments made on behalf of other financial institutions and their account holders.  In turn, these financial institutions can parcel out earnings to clients without revealing the individual investors' identities to the IRS.  Additionally, the portfolio discusses how the new tax regulations for foreign persons with U.S. source income have been integrated with the domestic reporting and backup withholding requirements. 

Carol advises clients on international tax matters, including providing advice to U.S. corporations on their foreign activities and to foreign clients about the U.S. tax consequences of their U.S. activities.

Formerly, Carol was with the IRS's office of Associated Chief Counsel (International) and a Special Assistant to the Assistant Commissioner (International).  While at the IRS, Carol a was a member of the International Withholding Task Force and a contributor to the Section 1441 withholding regulations. 

Sutherland Asbill & Brennan LLP is a national law firm known for solving challenging business problems and resolving unique legal issues for many of the nation's largest companies.  Founded in 1924, the firm has grown to more than 350 lawyers with offices in Atlanta, Austin, New York, Tallahassee and Washington.

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