Kiara L. Rankin
  1. Counsel

Ms. Rankin is counsel in Davis Polk’s Tax Department. She has extensive experience in all phases of tax controversy proceedings, including litigation and IRS 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 has also worked in-house at a global manufacturing company, where she was responsible for worldwide tax controversies.

Work Highlights

Before joining Davis Polk, Ms. Rankin’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) 

Professional History

  • 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


Practice Focus

Bar Admissions

  • State of New York
  • District of Columbia


  • B.A., Political Science, Bryn Mawr College, 2004
    • cum laude
  • J.D., George Washington University Law School, 2007
    • Articles Editor, American Intellectual Property Law Association Quarterly Journal