Kottke

Amanda T. Kottke

Partner
Baker & McKenzie LLP
Currently works from Minneapolis via a remote work arrangement.

Biography

Amanda Kottke advises domestic and international enterprises from a wide range of industries on US federal income tax issues, with a focus on resolving complex tax disputes and international tax controversies. She writes and speaks frequently on international tax topics related to global tax dispute resolution, privilege, and transfer pricing considerations.

Practice Focus

Ms. Kottke's practice involves all stages of federal income tax disputes, including audit preparation and management, administrative appeals, alternative dispute resolution, and litigation. She has extensive experience resolving disputes involving transfer pricing, subpart F, and foreign tax credit issues. Ms. Kottke also regularly advises clients on high technology tax issues, cross-border transactions, and transfer pricing matters. She assists clients in the high-technology, consumer products, medical device, and consumer goods and retail sectors, among others.

Representative Legal Matters

  • NIKE, Inc. & Subsidiaries v. Commissioner, T.C. Docket No. 16869-16 (full IRS concession prior to filing Answer).

  • Represented high-technology company in transfer pricing dispute during examination and before IRS Appeals.

  • Advised US-based multinational company on privilege considerations, including best practices and risk management strategies.

  • Assisted in reorganization planning efforts to integrate acquired foreign entities into foreign structure for US-based multinational company.

  • Counseled US-based multinational company with various issues related to cost-sharing.

  • Represented consumer goods and retail company in transfer pricing dispute during examination and before IRS Appeals.

  • Advised US-based multinational company regarding implications of the Tax Cuts and Jobs Act as it related to foreign licensing structure.

  • Represented US based multinational company before IRS Advance Pricing and Mutual Agreement with respect to US and UK transfer pricing matter.

  • Advised US based high technology company regarding financial reporting risks and compliance.

  • Obtained dismissal of worthless stock issue by IRS Examination team for large US based multinational company.

  • Defended retail company on research credit claim covering multiple years.

Professional Associations and Memberships

  • State Bar of California
  • State Bar of Minnesota
  • American Bar Association, Taxation Section
  • American Bar Association, Litigation Section

Admissions

  • California~United States (2010)
  • Minnesota~United States
  • U.S. Court of Appeals, Ninth Circuit~United States (2011)
  • U.S. District Court, Northern District of California~United States (2011)
  • U.S. Tax Court~United States (2011)

Education

  • University of California, Hastings College of the Law (J.D.) (2010)
  • San Jose State University (2006)
  • University of Wisconsin-Madison (B.A.) (2004)

Languages

  • English
  • French
  • Spanish

Previous Offices

  • San Francisco

Presentations

  • Preparing for IRS Interviews – Are Your Engineer, Tax Accountant and CFO Ready?, Tax Executives Institute 2019 Audits & Appeals Seminar, Minneapolis, 21 May 2019

  • Instructed at NITA’s Training the Child Advocate: A Trial Advocacy Program, 22-24 August 2018 (with Baker and NITA instructors)

  • International Tax Disputes, Multijurisdictional Audits, APAs, and MLI, Tax Executives Institute, Salt Lake City Chapter, 15 February 2018 (with J. Myszka)

  • US Tax Audits and Disputes, Tax Executives Institute, Nevada Chapter, 14 February 2018 (with J. Myskza)

  • Tax Developments in Emerging and Growth Leading Economies, Tax Executives Institute, International Day, Dallas, 4 February  2016 (with L. Martinez-Carbajo, A. Stamato, and S. Yuan)