Kate Kerrigan

Experience

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  Law Firm

  Jan 1986 - Jan 2000

  Commercial Litigation Associate

  Complex commercial litigation representing clients in both federal and state matters, typically multi-party multi-district cases at law firms with national client practices. Took depositions, drafted pleadings, wrote legal briefs. Extensive large case management. Negotiated settlement of numerous cases, involving multiple parties. Substantial client exposure, daily client contact.

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  Deloitte National Tax

  Jan 2000 - Jan 2004

  Management Development Program

  National Tax Office. Selected from nationally competitive tax program.

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  Grant Thornton

  Jan 2004 - Jan 2006

  Manager

  National Office resource for tax controversy, national tax solutions technical development. Instructed at numerous national tax webcasts and trainings.

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  US Tax Court

  Jan 2007 - Jan 2008

  Attorney Advisor to US Tax Court Judge David Laro

  One year appointed position. Primary drafter of eight federal tax opinions, including four division opinions. Opinions covered broad range of federal income tax issues including character of gain, penalties, deductions and timeliness of notice. Assisted with Georgetown University Law Center tax law planning and teaching.

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  Pricewaterhouse Coopers, National Office

  Jan 2008 - Jan 2011

  Manager

  Identify and analyze clients' cross-border intercompany transactions. Conduct functional interviews. Develop and review transfer pricing documentation. Draft and edit IDR responses. Review and coordination APA Annual Reports. Prepare memoranda regarding case evaluation, negotiating position. IRS Audit. Case administrative management including billing, SOWs, engagement letters.

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  APMA, Advanced Pricing and Mutual Agreement Program

  Sept 2011 - Aug 2018

  Team Leader and Country Coordinator for Canada

  Analyze, develop strategy, draft position papers, and negotiate transfer pricing cases arising under the advance pricing and mutual agreement procedures, primarily with Canada, Japan, UK, India. Industries worked include negotiation includes financial services, automotive, airline, consumer goods. Coordinated transfer pricing negotiations meetings between the United States and Canada. Develop case strategy, meet, and work closely with taxpayer representatives, US taxpayers, IRS international examiners and specialists to close cases in the context of US fiscal interests and foreign tax authority claims. Income Shifting Steering Committee. Financial Services Issue Team. Show less

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  Internal Revenue Service

  Sept 2018 - now

  IRS Chief Counsel, Large Business & International

  Division Counsel, Washington DC. Controversy and Transfer Pricing. Support IRS Exam Teams with audit analyses, NOPAs, IDRs, taxpayer meetings and presentations before Office of Appeals. Work closely with Exam on technical tax issues including transfer pricing, valuation, intellectual property transfers, documentation and also research and development.