Kathy Pakenham

Partner

Tax

“She is a master at her craft, with the experience to back it up.” (Chambers USA 2024, Tax: Controversy (Nationwide))

Kathy Pakenham

Overview

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.

Read More

Experience

  • (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

Education

  • 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

Admissions

  • 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

Expand All

Recognitions

  • Chambers High Net Worth, Tax: Private Client (USA – Nationwide), 2026
  • Chambers USA, Tax: Controversy (Nationwide), 2012−2026
  • Legal 500 U.S., U.S. Taxes: Contentious, 2012 and 2013, 2016−2021, and 2023–2026
  • The Best Lawyers in America©(BL Rankings, LLC), (New York): Tax Law, 2016−2020, 2024–2027
  • Selected to the 500 Global Tax Lawyers, Lawdragon, 2025 and 2026
  • 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
Insights

Events

Vinson & Elkins Sponsoring and Speaking at TEI Annual Conference

Vinson & Elkins is a platinum sponsor of the 2026 TEI Annual Conference, taking place October 18–21 in Nashville, Tennessee. …

October 18–21, 2026

October 18–21, 2026 • 1-minute read

Podcasts

Powering Progress Episode 11 – The Incentive Challenge: Navigating the New Tax Landscape for Data Centers

As AI infrastructure investment accelerates, developers, investors, and operators are making long-term decisions based on assumptions about power, financing, and …

August 17, 2026

August 17, 2026 • 7-minute read

Articles

How Data Center Developers Can Adapt to Tax Incentive Reversals

Partner Kathy Pakenham examined the growing uncertainty surrounding state tax incentives for data center developers as lawmakers across the country …

July 23, 2026

July 23, 2026 • 1-minute read

Events

Vinson & Elkins Sponsoring and Speaking at the NYU Tax Controversy Forum

Vinson & Elkins is a Gold sponsor of the NYU Tax Controversy Forum, taking place June 25–26 in New York. …

June 25, 2026

June 25, 2026 • 1-minute read

Events

Kathy Pakenham Presenting at the TEI DFW Chapter Tax School Conference

Partner Kathy Pakenham is scheduled to participate in a panel discussion on the “State of the IRS” at the Tax …

April 21, 2026

April 21, 2026 • 1-minute read

News & Achievements