Head of White & Case's Global Tax Practice, Kim Marie Boylan is a highly respected tax attorney. She has a long track record of creating innovative, practical approaches for the successful resolution of tax disputes. A renowned tax litigator, she also effectively utilizes the IRS's administrative appeals procedures, fast track, mediation and other alternative dispute resolution processes. Kim represents a broad spectrum of companies in connection with sophisticated domestic and international tax issues. Her practice focuses mainly on civil tax matters, but throughout her career, she has also successfully represented clients on criminal tax matters.
As recognized authority on privilege, Kim often advises companies in connection with the complicated issues that arise in this area, and numerous clients seek her knowledge and insight in judicial proceedings in the United States Tax Court, United States Court of Federal Claims, and in various district and appellate courts. Her practice encompasses transfer pricing, as well as the Advance Pricing Agreement process, an area of practice that is greatly enhanced by her credentials as a Certified Public Accountant. Kim has also testified on clients' behalf before the United States Treasury Department, Internal Revenue Service and the Financial Accounting Standards Board.
Many of Kim's cases are never made public because of her success in resolving tax disputes at the administrative level. Recent successes include obtaining an almost 90 percent concession of a cost sharing buy-in issue for a global company undergoing an IRS audit and settling a contentious audit involving novel issues in the insurance industry through the IRS Fast Track process, again obtaining an almost complete IRS concession. Kim is also one of only a handful of tax controversy lawyers representing a Swiss bank in connection with the U.S. Department of Justice's Program for Non-Prosecution or Non-Target Letters for Swiss Banks.
Notwithstanding her success at resolving cases short of litigation, Kim is a skilled litigator who has litigated some of the seminal cases in tax controversy over her almost 30 year career. Examples include 'United Parcel Service of America v. Commissioner (economic substance)' and 'Riggs National Corporation & Subsidiaries v. Commissioner (foreign tax credits)'. She was also involved in virtually every case in the series of cases that culminated in the U.S. Supreme Court's recent decision in Home Concrete & Supply, LLC v. United States (six-year statute of limitations). Unlike many tax litigators, Ms. Boylan is skilled at handling cases in all three potential tax litigation forums – the United States Tax Court, the United States Court of Federal Claims, and the various United States district courts. Clients know that her development of a case at the administrative level always takes into account possible litigation and her cases are managed with that possibility in mind.