Transfer Pricing 2026

USA Law and Practice Contributed by: Kevin Spencer, Kim Marie Boylan, Nicholas Wilkins and Christina Culver, White & Case LLP

White & Case LLP is a global law firm with long- standing offices in the markets that matter today. The firm’s on-the-ground experience, cross-border inte - gration and depth of local, US and English-qualified lawyers help clients work with confidence in any one market or across many. Clients rely on the firm’s ex - tensive experience and technical knowledge, and on its global tax presence for sophisticated and practi - cal advice to reach their business goals. The firm’s lawyers work closely with its other leading transac -

tional practice areas to provide integrated tax advice necessary to successfully complete transactions. Whether a dispute is anticipated, is already at the audit or administrative settlement stage, or has pro - gressed to encompass alternative dispute resolution techniques or litigation, the firm works closely with clients to develop the most effective and creative so - lutions. It also helps clients assess their global tax risk and works with them to develop strategies for mitigating that risk.

Authors

Kevin Spencer heads White & Case LLP’s tax controversy practice. He resolves complex tax matters on behalf of businesses, tax-exempt entities, and high net worth individuals. Kevin has substantial experience in

Nicholas Wilkins is counsel in White & Case LLP’s tax group. Nick has worked on a variety of tax matters, including federal tax litigation, domestic tax disputes with the Internal Revenue Service at the

assisting clients with resolving disputes with the Internal Revenue Service (IRS) at IRS Appeals, the Examination Division/Audit Division and the US competent authority, as well as litigating tax disputes in federal court (US Tax Court, US District Court, US Court of Federal Claims, and US Courts of Appeals). In addition to his tax controversy practice, Kevin advises clients on various tax issues, including tax accounting, civil and criminal tax penalties, IRS procedures, reportable transactions and tax shelters.

examination and appeals levels (including ADR such as fast-track settlement), tax-exempt organisation issues, and international tax issues. He also has extensive experience in transfer pricing, in both the advance pricing agreement and controversy contexts.

Christina Culver is an associate in White & Case LLP’s tax controversy group, based in Washington, DC, where her practice focuses on

Kim Marie Boylan is the former head of White & Case LLP’s tax controversy practice and was the head of the firm’s global tax practice for seven years. Kim serves on various committees at White & Case LLP and

representing taxpayers in proceedings before the Internal Revenue Service (IRS) at all levels. Christina’s representations include multinational corporations in transfer pricing disputes and advance pricing agreement negotiations with the IRS and foreign tax authorities. She has extensive experience with the IRS at both the examination and appeals levels, as well as with federal and international tax litigations. Prior to joining White & Case LLP, Christina clerked at the US Tax Court.

chaired the firm’s mandatory disclosure regime and DAC6 committee. She has a long track record of creating innovative, practical approaches for the successful resolution of tax disputes. A renowned tax litigator and transfer pricing expert, Kim also effectively utilises the Internal Revenue Service’s administrative appeals procedures, fast-track settlement, mediation, and the mutual assistance procedures for treaty-based disputes. Under her leadership, the practice and group members have received numerous awards and prestigious rankings.

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