Kent advises multinational clients on an array of issues involving transfer pricing, tax dispute resolution, and tax planning. He has experience with advance pricing agreements and income tax treaties, including permanent establishment matters and mutual agreement procedure resolutions. Kent handles corporate tax planning for domestic and international transactions, including mergers and acquisitions and restructurings.
Representative Legal Matters
- Medtronic, Inc. v. Commissioner, TC No. 6944-11.
- Represented multinational companies in unilateral and bilateral Advance Pricing Agreements involving the United States and various foreign jurisdictions, including China, India, Japan, Korea and the Netherlands.
- Represented multinational companies in mutual agreement procedure matters between the United States and various foreign jurisdictions, including China, India, Korea, and Germany.
- Advised multinational technology company on its global transfer pricing documentation with emphasis on EMEA (involving over 40 jurisdictions).
- Advised multinational company in the food industry on strategic reorganization (involving over 40 jurisdictions).
- Advised multinational company on the global restructuring relating to the spin-off of its commercial and residential security business (involving over 40 jurisdictions).
- Advised multinational company on the integration of European operations relating to the acquisition of a home appliances manufacturer (involving over 25 jurisdictions).
- Advised multinational company in the discount retail industry on the restructuring of Asian operations.
- Advised multinational company in the aviation industry on M&A transactions.
Professional Associations and Memberships
- Federal Bar Association - Section on Taxation, Young Tax Lawyers - Co-Chair (2013-2014; 2014-2015; 2015-2016)
- American Bar Association - Member
- District of Columbia~United States (2014)
- Florida~United States (2012)
- U.S. Tax Court~United States (2012)
- Georgetown University Law Center (LL.M. Taxation with Distinction) (2012)
- Tulane University Law School (J.D.) (2011)
- University of Southern Indiana (Bachelor of Science in Business Administration) (2002)
Co-author, “APMA's New Model Signals Move Toward Profit Splits,” Baker McKenzie North America Tax News and Developments, Client Alert, March 6, 2019
Co-author, “OECD and European Commission Release Reports on the Digital Economy; United States Confirms Its Stance,” Baker McKenzie North America Tax News and Developments, Volume XVIII, Issue 4, May 2018
Author, "Tax Court Swiftly Rejects IRS Argument That Closing Agreement is Not Relevant in USD 3.3 Billion Transfer Pricing Case," Baker McKenzie North America Tax News and Developments, Volume XVII, Issue 10, November 2017
Co-presenter, “Impact of US Tax Reform on non-US Tax Disputes,” Baker McKenzie’s Global Tax Disputes Forum, Milan, Italy, February 2019
Guest Lecturer, “U.S. Transfer Pricing Regulations,” International Tax Center Leiden, the Netherlands, January 2019
Co-presenter, “US Transfer Pricing Developments And Their Global Impact,” 7th Annual Africa Transfer Pricing Summit, Johannesburg, South Africa, November 2018
Co-presenter, “US Tax Reform,” Baker McKenzie’s EMEA Tax Planning and Transactions Conference, London, England, October 2018
Co-presenter, “US Policy and Tax Reform (Inbound),” Baker McKenzie London Annual Tax Seminar, London, England, May 2018