Stefanie E. Kavanagh

• Representing multinational companies on unilateral, bilateral, and multilateral advance pricing agreements (APAs) involving the IRS and other tax authorities.
• Assisting multinational companies to secure favorable competent authority agreements to eliminate double taxation in controversies involving the U.S., Canada, France, Germany, Italy, Japan, Mexico, Switzerland, and the UK.
• Secured favorable discretionary relief from the IRS under tax treaty limitation on benefits provisions.
• Assisting companies in maximizing the benefits of tax credits under the Inflation Reduction Act of 2022, including transfer pricing implications.
• Sustaining the deductibility of Sec. 174 research expenses in a post-Tax Cuts and Jobs Act amortization environment.
• Advised companies on transfer pricing planning, including related to the base erosion anti-abuse tax, cost allocation approaches, and ESG initiatives.
• Advised clients on federal tax issues concerning the effect of COVID-19 and related supply chain disruptions, including deductibility of expenses, shut-down issues, net operating losses, and the impact on APAs.
• Assisting multinational companies in the preparation and implementation of complex intercompany agreements.
• Advising multinational companies on restructuring projects and tax treaty planning.
• Represented issuers and underwriters in billions of dollars of offerings of REIT securities.
• Represented numerous REITs on mergers, including an industry-leading mortgage REIT on its merger with a specialty finance REIT that focuses primarily on investments in residential mortgage-backed securities.
• Counsel to multinational companies during internal reorganizations and spinoffs.

Stefanie Kavanagh focuses her practice on transfer pricing, tax planning, and structuring for domestic and international business entities. She assists multinational corporate clients with complex cross-border tax issues, including securing advance pricing agreements and competent authority relief from the IRS and foreign tax authorities. Stefanie also advises REITs (both privately owned and publicly traded) on numerous tax issues and assists with taxable and nontaxable acquisitions and dispositions, and public offerings of equity and debt securities. Since 2021, Stefanie has been identified as “One to Watch” by The Best Lawyers in America^® in Tax Law.

Before joining Alston & Bird, Stefanie was an intern with the financial institutions and products division of the Office of Chief Counsel of the IRS and the United States Tax Court while completing her LL.M. in taxation at the Georgetown University Law Center. She received her J.D. from the Vanderbilt University Law School and her B.A. in economics and political science, summa cum laude, from Westminster College.

律師資格

• 哥倫比亞特區
• 馬里蘭州

學歷

• Georgetown University (LL.M. Taxation, 2015)
• Vanderbilt University (法學博士, 2014)
• Westminster College (學士學位, 2011)

Memberships