Profile
Katy Stone focuses her practice on tax controversy and litigation, centering on complex areas such as international tax, multistate income apportionments, remote worker and payroll taxes, and administrative procedures. She represents an array of clients ranging from multinational corporations, partnerships, and financial institutions, to tax-exempt organizations and individuals. She navigates the intricate landscape of federal and state income tax controversies at various stages, including audits, administrative appeals, and judicial proceedings.
Katy has represented clients before the U.S. Tax Court and the U.S. Court of Federal Claims, as well as various taxing authorities in contentious tax matters. Additionally, Katy assists companies in tax planning and multistate income apportionment analysis.
Capabilities
Experience
- Advised an employer on multistate personal income tax withholding requirements on novel compensation.°
- Advised an employer on multistate personal income tax withholding requirements for a hostile employee.
- Represented a California business in sales tax correction matter.°
- Represented a non-resident LLC in California market sourcing matter.°
- Represented a client with an S Corp structure in sports and entertainment acquisitions.°
- Advised an investment company on the intersection of charitable contribution and self-dealing rules.°
- Represented an international tech company in an internal restructuring, buy-in, and cost sharing arrangement.°
- Advised an employer on income inclusions for private jet and private car services for executives.°
- Advised a company on group exemption and private foundation considerations prior to launching charitable operations.°
- Advised a foreign charity on federal and state tax issues for domestic “friends of” organizations.
- Advised a foreign company on 409A corrections for U.S. board member compensation.°
- Advised a non-resident S Corp on California income apportionment variance petition.°
- Advised an employer about preservation of Section 530 relief.°
- Represented a multinational technology company in connection with an IRS audit of its cost sharing arrangements relating to the development of technology products.°
- Represented a professional services company in relation to a third-party subpoena in a tax dispute before the U.S. Court of Federal Claims.°
- Represented Amgen Inc. in a transfer pricing case concerning the licensing of complex biopharmaceutical products before the U.S. Tax Court.°
- Represented a U.S. financial institution in a Massachusetts excise tax dispute before the Appellate Tax Board.°
- Represented a professional services company in a New York state income apportionment controversy before the Division of Tax Appeals.°
- Advised a U.S. telecom company in its multistate income apportionment analysis.°
- Represented a New York non-operating foundation in administrative matters during the COVID-19 pandemic.°
- Represented a trafficking victim in T-Visa application and cooperation with U.S. DHS, U.S. DOJ and NY DOL investigations into a large, international trafficking conspiracy.°
- Represented a taxpayer in innocent spouse petition docketed with U.S. Tax Court.°
- Represented several taxpayers in submitting federal offers in compromise.°
- Represented several taxpayers in submitting California FTB offers in compromise.°
- Assisted the U.S. Tax Court by counseling pro se litigants during a San Francisco docket call.°
°The above representations were handled by Ms. Stone prior to her joining Greenberg Traurig, LLP.
- Legal Intern, VMware, 2016
Recognition & Leadership
- Chief Financial Officer and Compliance Chief, Palo Alto High School’s TEAM (Together Everyone Achieves More), 2020-2022
- Scouts BSA, 2014-Present
Credentials
-
J.D., University of Chicago Law School
- Doctoroff Business Leadership Fellow
- Visiting Student, Stanford Law School
- Research Assistant, Professor Joseph Bankman, Stanford Law School
- LL.M., Taxation, New York University School of Law
- B.A., summa cum laude, New Saint Andrews College
- California
- U.S. Tax Court