Founder and Managing Member
Oscar is the Founder and Managing Member of OCP Tax Law PLLC. He concentrates his practice on international tax planning and tax controversy matters, advising multinational corporations and high-net worth individuals with complex cross-border transactions. Oscar has extensive experience developing and implementing tax-efficient strategies designed to optimize compliance and minimize tax exposure across multiple jurisdictions.
In addition to his tax planning and tax structuring practice, Oscar has successfully represented clients before the Internal Revenue Service in examination, administrative appeals, and proceedings before the United States Tax Court. He has also achieved significant results in IRS penalty abatement matters, helping clients obtain more than $50 million in penalty relief.
Oscar began his tax career with the International Tax Department of a Big 4 Accounting Firm and spent several years advising large multinational corporations on both inbound and outbound tax matters. He later joined a tax boutique law firm where he led the international tax engagements while also expanding his practice to include sophisticated tax controversy representation.
With nearly a decade of experience practicing tax law, Oscar advises clients on a broad range of inbound and outbound international tax matters including CFC rules, foreign tax credits, withholding taxes, tax treaties, GILTI/NCTI, FDII/FDDEI, BEAT, PFICs, FIRPTA and sourcing rules. He further assists clients with the preparation and reporting of complex foreign information returns and international tax compliance filings such as IRS Forms 5471, 5472, 8621, 8858, 8865, 926, 8938, 8991, 8992 and 8993.
Beyond international taxation and tax controversy, Oscar’s practice also encompasses purely domestic corporate taxation, state and local tax matters, M&A and corporate governance.
Education
Bar Admissions
Court Admissions
YOUR TAX STRATEGY SHOULD BE STRUCTURED,
DEFENSIBLE & TRULY ALIGNED WITH YOUR BUSINESS GOALS.
Oscar Carrillo’s profile already explains his professional background and credentials. A separate reason clients may need his involvement is when one tax problem touches several legal issues at once. Those matters often require a strategy that stays consistent from planning through reporting, examination, or transaction execution.
An international tax attorney may need to review ownership, residency, income source, withholding, or entity structure before a position reaches a return. International tax planning is most useful when those facts can still be evaluated before a transaction or change in status becomes fixed.
A tax controversy attorney focuses on the legal and procedural side of a dispute. When an examination begins, an IRS audit attorney may need to organize responses, define the issues, and preserve the record. If the matter later moves toward court, a tax litigation attorney must work from the facts and arguments developed earlier in the process.
A defined acquisition or sale can create issues that no longer belong only to general planning. An M&A tax attorney may need to review how transaction structure, tax provisions, diligence findings, and post-closing obligations fit together with the client’s broader objectives.
Complex matters can change category over time. A cross-border structure may create a compliance issue. A filing issue may become an IRS dispute. A planned exit may become a negotiated transaction. The value of coordinated counsel is not to combine every service into one page, but to make sure the legal position does not change unnecessarily as the matter develops. Oscar’s profile should therefore guide users toward International Tax, Tax Controversy, and M&A when those pages better match the immediate issue.
