Kathy Pakenham
The Grace Building
1114 Avenue of the Americas
32nd Floor
New York, New York 10036
She is a master at her craft, with the experience to back it up (Chambers USA 2024, Tax: Controversy (Nationwide)) Kathy is Co-Head of the firm’s Tax Controversy Practice. She is one of the nation’s most sought-after tax controversy lawyers. She has represented clients in major tax controversies relating to a full range of tax issues, with particular emphasis on partnership tax, transfer pricing, valuation, and tax procedure. Kathy has extensive experience advising clients at the pre-litigation phase, in particular examinations and administrative appeals under the centralized partnership audit regime under the Bipartisan Budget Act. She also represents clients involved in internal and governmental investigations, in addition to state and federal trial and appellate matters. Her clients include Fortune 500 companies and large partnerships in diverse sectors such as banking, energy, private equity, technology, and pharma.
Kathy has been recognized consistently as a leader in the tax litigation and controversy practice area by Chambers USA and The Legal 500 U.S. One client notes “She is incredibly knowledgeable” (Chambers USA 2025). Additionally, she was appointed to the prestigious United States Attorney General’s Honor Program immediately after her graduation of law school. Kathy also clerked for the Honorable Steven M. Gold of the United States District Court for the Eastern District of New York after graduating from law school.
Experience Highlights
(IRS Audit) – Representing private equity portfolio company in audit of disguised sale issues arising from partnership acquisition
(IRS Audit) – Represent multinational conglomerate in examination of partnership basis items (ongoing)
(IRS Appeals) – Representing global distributor in transfer pricing dispute, resulting in more than 95% IRS concession
(U.S. Tax Ct.) – Lead trial counsel for supermajor oil and gas company in partnership tax issues arising from divestment of joint venture agreement
(N.D. Okla.); (10th Cir.) – Representing a global oil and gas company on issues relating to construction of a closing agreement
(E.D. La.) – Representing integrated energy company on statute of limitations and equitable recoupment issues
(D. Idaho) – Obtained rare quashing of IRS summons based on violations of the Taxpayer Bill of Rights
(S.D. Ohio) – Successful summary judgment motion for a major national insurance company related to tax reserve computations, reversing negative TAM
(U.S. Tax Ct.) – Representing a global mining company in dispute with IRS over foreign tax credits and termination payment of a forward contract; resolved with no change
(IRS Audit) – Representing a major natural resources company in complex transfer pricing dispute with IRS; resolved with no change
(IRS Appeals) — Representing pharmaceutical company in proposed disallowance of research and development credits, resulting in 100% IRS concession
(IRS Audit) — Representing a multinational media company on audit related to cross-border hybrid transaction and foreign currency exchange issues, resulting in a 100% concession by the IRS and avoiding designation for litigation
(IRS Appeals) – Representing a global mining company on transfer pricing, IRC § 195 startup costs, and subsidiary expense issues
(U.S. Tax Ct.); (8th Cir.) – Trial and appellate counsel in precedent setting case involving the interpretation of IRC § 274 and reversing adverse TAM for a national professional employer organization
Credentials
- New York University School of Law, LL.M. Taxation, 1998
- Brooklyn Law School, J.D., 1995
- State University of New York at Albany, B.A., 1992
- Judicial clerk to the Honorable Steven M. Gold, United States District Court for the Eastern District of New York, 1996–1997
- Attorney, U.S. Department of Justice, 1995–1996
- Chambers USA, Tax: Controversy (Nationwide), 2012−2025
- Legal 500 U.S., U.S. Taxes: Contentious, 2012 and 2013, 2016−2021, and 2023–2025
- The Best Lawyers in America©(BL Rankings, LLC), (New York): Tax Law, 2016−2020, 2024–2026
- Selected to the 500 Global Tax Lawyers, Lawdragon, 2025
- International Tax Review: World Tax Review, Leading Lawyer list, 2024
- Crain’s New York Business, 100 Leading Women Lawyers, 2017
- Selected to the New York Super Lawyers list, Super Lawyers (Thomson Reuters), 2006−2025
- New York Law Journal, Distinguished Leader of the Year, 2019
- American Bar Association
- New York State Bar Association
- New York
- U.S. Court of Appeals for the Second Circuit
- U.S. Court of Appeals for the Third Circuit
- U.S. Court of Appeals for the Eighth Circuit
- U.S. Court of Appeals for the Tenth Circuit
- U.S. District Court for the Eastern District of New York
- U.S. District Court for the Southern District of New York
- U.S. Court of Federal Claims
- U.S. Tax Court
- EventDecember 13, 2025
- InsightSeptember 3, 2025
Published by Tax Executive on June 25, 2025
- Rankings & AwardsAugust 21, 2025
- Rankings & AwardsJune 11, 2025
- Rankings & AwardsJune 5, 2025
- Rankings & AwardsMay 27, 2025
- InsightMarch 20, 2025
V&E Tax Update
- InsightMarch 6, 2025
- InsightFebruary 12, 2025
V&E Energy Update
Published by Energy Intelligence and Hart Energy, March 2025
- InsightJanuary 13, 2025
V&E Tax Update
- Event RecapNovember 7, 2024
- Rankings & AwardsNovember 1, 2024
- Event RecapJuly 11, 2024
- InsightJuly 3, 2024
V&E Tax Update
- InsightJuly 1, 2024
V&E Tax Update
- InsightJune 18, 2024
V&E Tax Update
- Rankings & AwardsJune 12, 2024
- Rankings & AwardsJune 6, 2024
- Event RecapMay 8, 2024
- InsightOctober 9, 2023
V&E Tax Update
- Rankings & AwardsSeptember 22, 2023
- Rankings & AwardsAugust 28, 2023
- Rankings & AwardsAugust 21, 2023
- Rankings & AwardsJune 12, 2023
- Rankings & AwardsJune 1, 2023
- Press ReleaseJanuary 30, 2023
- “Taxes and Tariffs in the Summer of 2025,” Tax Executives Institute (TEI) Webinar, July 17, 2025 (panelist)
- “State of the IRS,” Tax Executives Institute (TEI) – Dallas Chapter Tax School, April 22, 2025 (speaker)
- “What Every Tax Department Needs to Know About Tariffs,” Tax Executives Institute (TEI) Webinar, April 15, 2025 (panelist)
- “IRS Dispute Resolution Tools: What’s New, What’s Working, and What Isn’t,” Tax Executives Institute (TEI) Midyear Conference, March 17, 2025 (panelist)
- “Welcome to the New Era of Tax Enforcement Relating to Partnerships and the Economic Substance Doctrine,” American Bar Association (ABA) Criminal Tax Fraud and Tax Controversy Conference, December 13, 2024 (panelist)
- “Ethics for the In-House Tax Practitioner,” Tax Executives Institute (TEI) Ethics Webinar Series: Ethics CPE for Tax Professionals, December 10, 2024 (panelist)
- “Tax Inquiries, Audits and Regulatory Challenges – What Should We Expect?,” V&E Energy Transition & IRA Conference, November 7, 2024 (co-speaker)
- “IRS Strategic Operating Plan and Enforcement Update,” Tax Executives Institute (TEI) Annual Conference, October 29, 2024 (panelist)
- “Tales from the Front: Early Experiences with the IRS’s New Partnership Tax Organization,” Tax Executives Institute (TEI) Annual Conference, October 28, 2024 (panelist)
- “Prevailing Wage & Apprenticeship, Domestic Content & Energy Community Bonuses and Tax Controversies & Audits,” V&E Energy Transition & IRA Conference, May 8, 2024 (panelist)
- “What’s Old is New Again: The Return to Anti-Abuse and Substance Over Form to Attack Cross-border Transactions,” American Bar Association (ABA) Criminal Tax Fraud and Tax Controversy Conference, December 9, 2023 (panelist)
- “Positioning Issues for Resolution at IRS Appeals: What Has Changed and Remains the Same,” Tax Executives Institute (TEI) Annual Conference, October 25, 2023 (panelist)
- “Navigating Large Partnership Audits,” V&E Navigating Series CLE, October 12, 2023 (panelist)
- “The IRS’s New Enforcement Initiative: Navigating the Audit Process,” V&E Energy Series CLE, June 14, 2023 (co-speaker)