Carol Dunahoo

Carol A. Dunahoo

Baker & McKenzie LLP
Admitted in New York only. Practice limited to matters and proceedings before US courts and federal agencies.


Carol Dunahoo is a member of Baker McKenzie’s Tax Practice Group. She has more than 30 years of international tax experience, including both high-level US government positions and client service. Carol has been named a leading tax advisor in Chambers USA; World Tax, Guide to the World’s Leading Transfer Pricing Advisors; and The Best Lawyers in America. She is active in the International Fiscal Association, where she serves on the Executive Committee of the USA Branch and served a term on the global Executive Committee. She also serves on the advisory boards for the annual OECD and IRS/GW tax conferences in Washington, DC.

Practice Focus

Carol’s practice focuses on international tax controversies, compliance, and policy, including transfer pricing, tax treaty, tax policy and other matters. She previously served as the US Competent Authority and Director, International within the Large and Mid-Size Business Division (LMSB) at the US Internal Revenue Service, where she led US international tax administration efforts and was also responsible for the interpretation and application of US tax treaties, including advance pricing agreements and other competent authority matters.

Carol has represented the interests of the United States at meetings of the OECD’s Committee on Fiscal Affairs and of other multilateral organizations.

Representative Legal Matters

  • Advising and representing clients on transfer pricing, permanent establishment and other tax treaty issues.
  • Obtaining competent authority and advance pricing agreement resolutions.
  • Advising on other matters of tax treaty interpretation, negotiation and policy.
  • Advising on strategies in examinations and other domestic dispute resolution procedures.

Professional Associations and Memberships

  • United States Council for International Business - Tax Committee
  • International Fiscal Association - USA Branch Executive Council
  • National Foreign Trade Council - Tax Committee
  • BIAC - Tax Committee
  • Vienna Institute of Austrian and International Tax Law - LL.M. Program Instructor


  • U.S. Supreme Court~United States (1986)
  • New York~United States (1986)


  • Harvard Law School (JD) (1985)
  • University of Bonn (DAAD Fellowship) (1982)
  • Yale University (BA summa cum laude) (1981)


  • English
  • German