Transfer Pricing 2025

USA Trends and Developments

Trends and Developments Contributed by: Kim Marie Boylan, Kevin Spencer, Nicholas Wilkins and Sean Lyons White & Case LLP

White & Case LLP is one of the largest global law firms, with 44 offices in 30 countries on six continents. White & Case LLP provides practi - cal, creative solutions to its clients’ most com - plex legal and regulatory problems. The firm’s global tax practice includes more than 90 tax lawyers and tax consultants, who work seam - lessly with colleagues across its global platform to deliver results. White & Case LLP partners with clients to achieve optimal tax efficiency,

risk reduction, and avoidance or resolution of tax controversies. The firm’s culture is defined by three core values: pioneering (innovation and growth), united (one firm with a shared pur - pose), and human (caring for each other and the world). These values shape White & Case LLP’s unique culture, guiding the team’s actions to fulfil commitments to clients and colleagues alike.

Authors

Kim Marie Boylan heads 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 &

Kevin Spencer of White & Case LLP resolves complex tax matters on behalf of businesses, tax-exempt entities, and high net worth individuals. Kevin has substantial experience assisting

Case LLP and chairs 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, 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.

clients in 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.

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