Kiara L. Rankin
Kiara has extensive experience in all phases of tax controversy proceedings, including litigation and Internal Revenue Service administrative practice. She has represented multinational corporations, financial institutions and partnerships on a variety of issues, including transfer pricing, financial products and cross-border transactions.
She is recognized by Chambers USA as an “Up and Coming” lawyer in tax controversy work. A source quoted by Chambers says of Kiara: “She is an extremely strong lawyer. She is highly analytical and a force to be reckoned with.”
Kiara previously worked as in-house counsel at a global manufacturing company, where she was responsible for worldwide tax controversies.
Before joining Davis Polk, Kiara's tax representations include the following cases:
Eaton Corporation v. Commissioner—transfer pricing (U.S. Tax Court) Lehman Brothers Holdings Inc. v. United States—foreign tax credits involving cross-border stock lending transactions (SDNY) Salem Financial, Inc.(BB&T) v. United States—foreign tax credits involving cross-border financing (Court of Federal Claims and U.S. Court of Appeals for the Federal Circuit) Fidelity International Currency Advisor A Fund, L.L.C. v. United States—“Son of Boss” transaction (U.S. Court of Appeals for the First Circuit)
- Articles Editor, American Intellectual Property Law Association Quarterly Journal
- cum laude
- Counsel, Davis Polk, 2018-present
- Tax Counsel and Senior Director of Transfer Pricing Controversy, Eaton, 2016-2018
- Associate, Skadden, Arps, Slate, Meagher & Flom, 2014-2015
- Associate, Bingham McCutchen, 2009-2014
- Associate, McKee Nelson, 2007-2009