Agbayani, Kathleen A.

Kathleen A. Agbayani

Of Counsel
Baker & McKenzie LLP
Not admitted to practice law in this jurisdiction


Kathleen Agbayani is of counsel in the North American Tax Practice Group. She joined Baker McKenzie’s Washington, DC office after serving as an attorney-advisor for the Honorable Robert N. Armen, Jr., at the United States Tax Court. She is a committee member of the North American Tax Practice Group Tax Controversy Steering Committee and the Global Tax Practice Group Voluntary Disclosure Steering Committee. She has spoken at the American Bar Association Section of Taxation and The Tax Executives Institute.

Practice Focus

Ms. Agbayani focuses her practice on tax controversy, voluntary disclosures, global wealth management, and transfer pricing. She advises individual and corporate clients on a variety of substantive and procedural matters during examination and administrative audits before the Internal Revenue Service and assists in contesting disputes in court. Ms. Agbayani also provides pro bono advice to many pro bono clients including the American University Washington College of Law Janet R. Spragens Federal Tax Clinic and D.C. Tax Legal Assistance, American Bar Association Military Pro Bono Project.

Representative Legal Matters

  • Advised clients on voluntary disclosure issues.
  • Advised and represented multinational companies during examination and administrative audits before the Internal Revenue Service.
  • Advised foreign governments with respect to Sections 892 and 893 of the Internal Revenue Code.
  • Advised large multinational companies on their transfer pricing programs and APA agreements.
  • Advised and represented pro bono clients in matters of tax planning and tax controversies.

Professional Associations and Memberships

  • American Bar Association - Committee on Civil and Criminal Tax Penalties
  • American Bar Association - Tax Section
  • California State Bar Association - Tax Section


  • U.S. Supreme Court~United States (2005)
  • U.S. Tax Court~United States (2002)
  • California~United States (1997)


  • Georgetown University Law Center (LL.M. Taxation Distinction) (2002)
  • University of California at Los Angeles (J.D.) (1997)
  • University of California at Los Angeles (B.A. International Economics) (1990)


  • English
  • Japanese