Kent P. Stackhouse

Biography

Kent Stackhouse is a member of the Firm’s Global Tax Practice focusing in the areas of federal and international taxation. He previously was a member of the Firm’s Amsterdam office and a teaching associate at Georgetown University Law Center for an international tax and business planning course. Kent frequently speaks and writes on various areas of taxation.

Practice Focus

Kent advises multinational clients in the areas of federal and international tax dispute resolution and tax planning, with an emphasis on transfer pricing. He has significant experience with advance pricing agreements, mutual agreement procedure negotiations, and transfer pricing documentation. Kent also handles corporate tax planning for domestic and international transactions, including post acquisition restructurings.

Representative Legal Matters

Represented multinational companies in unilateral and bilateral advance pricing agreements involving the United States and various foreign jurisdictions, including Canada, China, India, Japan, Korea, and the Netherlands.
Represented multinational companies in mutual agreement procedure matters involving the United States and various foreign jurisdictions, including China, Germany, India, Korea, and the UK.
Advised multinational technology company on its global transfer pricing documentation with emphasis on EMEA (involving over 40 jurisdictions).
Medtronic, Inc. v. Commissioner, TC No. 6944-11.
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 - Member; Young Tax Lawyers - Co-Chair (2013-2014; 2014-2015; 2015-2016)
American Bar Association - Member

Admissions

District of Columbia~United States (2014)
Florida~United States (2012)
U.S. Tax Court~United States (2012)

Education

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)

Previous Offices

Amsterdam

Publications

Co-author, "OECD Statistics Show New MAP Cases (and Global Audits) on the Rise in 2019," Baker McKenzie North America Tax News and Developments, Volume XX, Issue 12, December 2020

Co-author, "2019 APMA APA Statistics Show Improvement," Baker McKenzie North America Tax News and Developments, Volume XX, Issue 5, May 2020

Co-author, "IRS Announces TCJA Compliance Campaign," Baker McKenzie North America Tax News and Developments, Volume XX, Issue 5, May 2020

Co-author, "Contemplating Force Majeure and Other Contractual Considerations in Intercompany Agreements," Baker McKenzie and Bloomberg Tax's Special Report: COVID-19: Impact on (the Other) TP, April 7, 2020

Co-author, "OECD Statistics Show New MAP Cases (and Audits) on the Rise," Baker McKenzie North America Tax News and Developments, Volume XIX, Issue 10, October 2019

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-author, "Protecting the Crown Jewels: Protective Orders in Tax Court," Tax Notes, Volume 153, Number 3, October 2016

Author, "Long-Awaited Final Regulations Under Code Section 336(e) Permit Election to Treat Stock Disposition as Asset Sale," Baker & McKenzie North America Tax News & Developments, Volume 13, Issue 3, June 2013

Author, "The Supreme Court Affirms Substance-Over-Form Analysis for Foreign Tax Credits in PPL Corporation v. Commissioner, Holds UK Windfall Tax Creditable," Baker & McKenzie North America Tax News & Developments, Volume 13, Issue 3, February 2013

Author, "New 'No-Rule' Areas Announced by IRS – Major Corporate Transactions Implicated," Baker & McKenzie North America Tax News & Developments, Volume 13, Issue 1, February 2013

Co-author, "US Supreme Court to address Creditability of UK Windfall Tax," International Tax Review, December 2012-January 2013

Author, "Tax Court Rules in Favor of Taxpayer's Characterization of Intercompany Advance as Debt, Allows Deduction for Interest Expense," Baker & McKenzie North America Tax News & Developments, Volume 12, Issue 4, August 2012

Presentations

Co-presenter, "Disputes and Resolutions," Tax Executives Institute, 2020 US Tax Conference, Singapore, November 2020

Co-presenter, "Transfer Pricing in a Global Pandemic - Losing Money the Old Fashioned Way, and What to Do About it," Baker McKenzie's 21st Annual Tax Leaders' Workshop, October 1, 2020

Guest Lecturer, “U.S. Transfer Pricing Regulations,” International Tax Center Leiden, January 2020

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

Co-presenter, "Foreign Perspectives on US Tax Reform, What Could This Mean for Your Business? Focus on US Companies with Presence in the Netherlands," Baker McKenzie Ahead of Tax Conference, Amsterdam, the Netherlands, April 2018

Co-presenter, "Overview of International Tax," Bloomberg BNA Government, Federal Taxation of U.S. Corporations, Washington, DC, September 2017

Co-presenter, "Introduction to U.S. International Tax Law," Institute for U.S. Law (IUSLAW), Washington, DC, August 2017

Co-presenter, "Understanding the US GAAP Implications (including FIN 48 aspects) of Overseas Planning Strategies: What Does Every International Tax Lawyer Need to Know?" Baker McKenzie EMEA Tax Conference, Munich, Germany, June 2017

Co-presenter, "Transfer Pricing for Intangibles," Bloomberg BNA, Hot Issues in International Taxation, Arlington, VA, March 2017

Co-presenter, "Transfer Pricing in the Age of BEPS," Bloomberg BNA, Hot Issues in International Taxation, Arlington, VA, March 2017

Co-presenter, "Foreign Base Company Income – Section 954," Bloomberg BNA, Intermediate U.S. International Tax Update, Las Vegas, NV, February 2017

Co-presenter, "Repatriation Strategies," Bloomberg BNA, Advanced International Tax Seminar, Las Vegas, NV, February 2017

Panelist, "CbC Reporting Requirements, Options, and Protecting Confidential Data," Tax Executives Institute – Austin, Austin, TX, December 2016

Panelist, "Parsing India's New Approach to Transfer Pricing," Bloomberg BNA, Global Transfer Pricing Conference: Asia, Hong Kong, China, September 2016

Panelist, "U.S. vs OECD Perspectives on the Final BEPS Transfer Pricing Report," Bloomberg BNA, Global Transfer Pricing Conference: Asia, Hong Kong, China, September 2016

Panelist, "Update on Global Transfer Pricing Developments," Baker & McKenzie Global Transfer Pricing Conference, Tokyo, Japan, September 2016

Panelist, "Parsing India's New Approach to Transfer Pricing," Baker & McKenzie Global Transfer Pricing Conference, Tokyo, Japan, September 2016

Panelist, "Protective Orders: Necessary Evil or Unnecessary Burden in Tax Court?," 2016 ABA Section of Taxation May Meeting, May 2016

Co-presenter, "Transfer Pricing Under Section 482," Bloomberg BNA, Introduction to US International Tax, Dallas, TX, May 2016

Co-presenter, "Event Programming Best Practices," Federal Bar Association Leadership Training Program, Arlington, VA, May 2015

Co-presenter, "Introduction to U.S. International Tax Law," Institute for U.S. Law (IUSLAW), Washington, DC, August 2014

Co-presenter, "Understanding the Rules for Computing Foreign Exchange Gain (Loss)," Bloomberg BNA, U.S. International Tax Planning, New York, NY, July 2014