Cary D. Pugh




Washington, D.C.

T: 1.202.371.7178

F: 1.202.661.8268


Download vcard vCard Icon

Cary D. Pugh focuses her practice on a wide range of administrative and legislative matters.  She represents clients in all stages of audit and controversy before the IRS and on published guidance and tax policy matters before the Treasury Department and Congress.  She also advises clients on planning and compliance issues, as well as energy tax matters. 

Prior to joining Skadden in June 2005 as counsel in the Tax Group, she served as special counsel to the chief counsel of the IRS where she advised on published guidance, tax administration and controversy matters, and led the chief counsel's expedited guidance program. Ms. Pugh was responsible for coordinating chief counsel implementation of the American Jobs Creation Act and was involved in developing guidance relating to the domestic manufacturing deduction, nonqualified deferred compensation, dividend repatriation, tax shelter disclosure and reporting requirements and penalty provisions. While with the Office of Chief Counsel, Ms. Pugh also worked on the design of the revised Schedule M-3, the IRS policy regarding tax accrual workpapers and Circular 230. In addition, she was involved in tax shelter and tax-shelter promoter initiatives and administration of the penalty provisions. Previously, Ms. Pugh served as tax counsel to the Senate Finance Committee, where she was responsible for advising committee members on individual and business tax issues, including international tax, corporate tax, pass-through entities, S corporations, tax accounting, tax-exempt bonds, energy tax and tax shelters.

Ms. Pugh has been a frequent speaker on bar panels and before industry groups on a variety of published guidance and tax administration topics, including tax accrual workpapers, the tax shelter disclosure and reporting regulations, application of penalties, attorney-client privilege and Circular 230.

Bar Admissions

United States Supreme Court
District of Columbia
United States Tax Court


J.D., University of Virginia School of Law, 1994 (Order of the Coif)

M.A., Stanford University, 1988

A.B., Duke University, 1987 (magna cum laude)


Adjunct Professor, Georgetown University School of Law (LLM Program)

Government Service

Special Counsel to the Chief Counsel of the IRS (2002-2005)

Tax Counsel and Minority Tax Counsel to the Senate Finance Committee (1999-2002)

Law Clerk to the Honorable Jackson L. Kiser, Chief United States District Court Judge for the Western District of Virginia (1994-1995)