USA Trends and Developments
Trends and Developments Contributed by: Sean Lyons, Nicholas Wilkins, Kevin Spencer and Kim Marie Boylan White & Case LLP
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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
Sean Lyons is an associate in White & Case’s tax controversy group, based in Washington, DC. Sean’s practice focuses on representing taxpayers in proceedings before the Internal Revenue Service (IRS), at both the
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 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. He has also represented taxpayers in both deficiency litigation before the US Tax Court and refund litigation in the US District Courts. Sean also routinely advises clients on international tax matters, with an emphasis on transfer pricing and tax treaty issues, including representing clients in negotiations between the IRS and foreign tax authorities for bilateral advance pricing agreements, and regarding requests for relief from double taxation pursuant to the mutual agreement procedures of bilateral income tax treaties.
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 examination
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
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.
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
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