Kim Marie Boylan | White & Case LLP International Law Firm, Global Law Practice
Kim Boylan
Kim Boylan

Kim Marie Boylan

Partner, Washington, DC

T +1 202 626 3685

T +1 202 626 3600

E kboylan@whitecase.com

Kim Boylan was named as a 2014 Tax Disputes Attorney of the Year in Washington, DC by Corporate INTL Magazine Global Awards.

Overview

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 a 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.

Kim is a frequent speaker on tax controversy, transfer pricing and accounting policy issues, and writes extensively on these issues. She is a member of the J. Edgar Murdock Inn of Court at the United States Tax Court, the American Bar Association and the District of Columbia Bar Association.

Bars and Courts

  • District of Columbia Bar
  • US Tax Court
  • US Court of Federal Claims
  • US Court of Appeals for the Seventh, Ninth, District of Columbia and Federal Circuits

Education

  • LLM, Georgetown University Law Center
  • JD, Syracuse University College of Law
  • BS, Georgetown University

Languages

  • English

Experience

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. This is the keystone of the U.S. Department of Justice's attempt to ferret out U.S. taxpayers who have failed to report their foreign bank accounts held in Swiss Banks. It is an unprecedented program that implicates civil as well as criminal tax matters.

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.

Speaking Engagements

"Effective Use of Alternative Resolution Strategies", May 2014: Tax Executives International Audits and Appeals Seminar – Insights and Skills for Tax Controversy Success

"Discovery Issues in Cross-Border Situations", June 1, 2012: Federal Bar Association Insurance Tax Seminar,
Washington, DC

"The Impact of the Supreme Court's Decision in 'US v. Home Concrete & Supply' Upon Doctrines of Stare Decisis and Judicial Deference to Regulations", May 29, 2012: Webinar

Publications

  • Upcoming lead author for new BNA Tax Portfolio on Privilege.
  • Absolute Power Corrupts Absolutely: Basis Overstatement and the Six-Year Limitations Period – Should the IRS Be Allowed to Re-Write the Law Retroactively?, 52 Tax Management Memorandum 235, Vol. 52, No. 12, June 6, 2011
  • Gift Card Programs: Will the IRS Allow Income Deferral for Giftcos?, Tax Notes, Vol. 130, No. 5 at 584, January 31, 2011
  • FASB Proposes Expanded Disclosures Regarding Loss Contingencies, ThompsonReuters (Practical US/Domestic Tax Strategies, Checkpoint 2010), July 22, 2010
  • IRS Seeks To Overturn Court Losses Through Issuance of Retroactive Regulations, ThompsonReuters (Practical US/Domestic Tax Strategies, Checkpoint, and the Lawyer's Brief 2009)
  • The Section 7525 Tax Practitioner-Taxpayer Privilege and Related Issues, BNA Accounting Policy & Practice Portfolios, July 2007

Awards & Recognition

Global Law Experts Tax Disputes Law Firm of the Year - 2016

Named in ITR Tax Controversy Leaders Guide, 2015

Named in Euromoney's Women in Business Law Awards, 2015

2014 Corporate Intl Magazine Global Award – Tax Disputes Attorney of the Year in Washington, DC

Tier 1 – National Tax Litigation, US News/Best Lawyers, 2014

Tier 1 – Washington, DC Tax Litigation, US News/Best Lawyers, 2014

Legal 500 USA—US: Tax Controversy Euromoney's Guide to the World's Leading Transfer Pricing Advisors