Stefanie Kavanagh is a partner in BakerHostetler’s Tax Practice Group who handles complex transaction matters involving transfer pricing, tax planning and structuring for domestic and international business entities, with a focus on multinational companies and cross-border transactions. She advises clients in an area where disputes are increasingly common, helping businesses navigate and resolve complicated issues, including transfer pricing matters, consistently identified in industry surveys as the most significant international tax risk.
Stefanie regularly assists multinational corporate clients with complex cross-border tax issues, including securing advance pricing agreements (APAs) and obtaining competent authority relief from the IRS and foreign tax authorities. Stefanie works closely with customs and trade colleagues, particularly as tariffs heighten the importance of intercompany pricing, helping companies mitigate tariff exposure while implementing tax-efficient operations.
Stefanie's practice also includes advising on tax treaty application. Stefanie helps clients interpret treaty provisions, address differences in entity classifications and structure outbound and inbound transactions to qualify for reduced withholding rates and other treaty benefits. She frequently counsels foreign companies entering the U.S. market on how to effectively utilize treaty protections and optimize tax outcomes. In addition, she considers how transfer pricing principles are embedded within treaty frameworks, including provisions related to arm’s-length standards and dispute resolution.
Stefanie collaborates closely with business and intellectual property teams, advising on how intercompany pricing impacts operational structuring and the movement of IP within multinational groups. She provides guidance on issues such as the acquisition and placement of IP portfolios, ensuring that pricing aligns across jurisdictions and supports overall tax efficiency.
Earlier in her career, Stefanie advised REITs, both privately held and publicly traded, on a wide range of tax matters. Her work included supporting taxable and nontaxable acquisitions and dispositions, as well as public offerings of equity and debt securities.
Stefanie co-authors a chapter on APAs in the leading transfer pricing treatise Practical Guide to U.S. Transfer Pricing (Matthew Bender) and has been recognized as “One to Watch” by The Best Lawyers in America in Tax Law.
