FacultyFaculty/Author Profile
Kathleen M. Pakenham

Kathleen M. Pakenham

Cooley LLP

New York, NY, USA


Kathleen Pakenham is co-chair of Cooley's Tax practice group and serves on the firm's Management Committee. Kathleen is a seasoned litigator in matters involving complex questions of federal tax law and procedure. She has represented clients in sizable tax controversies relating to tax shelter issues, options trading transactions, summons enforcement actions, tax fraud, subpoena requests and real property tax disputes. She has extensive experience advising clients at the pre-litigation assessment phase. She also represents clients involved in all types of internal and governmental investigations, in addition to state and federal trial and appellate matters. Her clients have included Fortune 500 companies in diverse industries such as banking, energy, telecommunications, and oil and gas.

Recent representations include:

  • Representing a global oil and gas company in US District Court and the US Court of Appeals on issues relating to construction of a closing agreement;
  • Successful summary judgment motion for a major national insurance company in US District Court related to tax reserve computations, reversing negative TAM;
  • Representing a global mining company in US Tax Court in dispute with IRS over foreign tax credits and termination payment of a forward contract;
  • Representing a major natural resources company in complex transfer pricing dispute with IRS;
  • Representing a global petroleum companies in pre-litigation resolution of disputes with IRS related to use of tracking stock;
  • 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;
  • Representing a global mining company before IRS Appeals on transfer pricing, IRC § 195 startup costs, and subsidiary expense issues;
  • Trial counsel in precedent setting case involving the interpretation of IRC § 274 and reversing negative TAM for a national professional employer organization in U.S. Tax Court and U.S. Court of Appeals;
  • Lead counsel in a week-long trial in U.S. Tax Court relating to a façade easement on a luxury condominium building valued at more than $75 million;
  • Conducting Fast Track mediation before the IRS relating to proposed disallowance of a $600 million loss from a corporate restructuring;
  • Representing more than a dozen witnesses in complex criminal tax shelter investigations; and
  • Negotiating successful resolution of Tier 1 issues.

Kathleen has been recognized consistently as a leader in the tax litigation and controversy practice area by Chambers USA and The Legal 500. Additionally, she was appointed to the prestigious United States Attorney General's Honor Program immediately after her graduation of law school. Kathleen 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.

Kathleen M. Pakenham is associated with the following items:
Live Seminar  Live Seminar Nuts and Bolts of Tax Penalties 2018: A Primer on the Standards, Procedures and Defenses Relating to Civil and Criminal Tax Penalties, Tuesday, March 20, 2018, New York, NY
Live Webcast  Live Webcast Nuts and Bolts of Tax Penalties 2018: A Primer on the Standards, Procedures and Defenses Relating to Civil and Criminal Tax Penalties, Tuesday, March 20, 2018, New York, NY
PLI Grpcast-Live Web  PLI Grpcast-Live Web Nuts and Bolts of Tax Penalties 2018: A Primer on the Standards, Procedures and Defenses Relating to Civil and Criminal Tax Penalties, Tuesday, March 20, 2018, Cleveland, OH
Nuts and Bolts of Tax Penalties 2018: A Primer on the Standards, Procedures and Defenses Relating to Civil and Criminal Tax Penalties, Tuesday, March 20, 2018, Philadelphia, PA
Nuts and Bolts of Tax Penalties 2018: A Primer on the Standards, Procedures and Defenses Relating to Civil and Criminal Tax Penalties, Tuesday, March 20, 2018, Pittsburgh, PA
Nuts and Bolts of Tax Penalties 2018: A Primer on the Standards, Procedures and Defenses Relating to Civil and Criminal Tax Penalties, Tuesday, March 20, 2018, Mechanicsburg, PA
Nuts and Bolts of Tax Penalties 2018: A Primer on the Standards, Procedures and Defenses Relating to Civil and Criminal Tax Penalties, Tuesday, March 20, 2018, New Brunswick , NJ
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