Rachel Borden is Counsel in the Tax and Tax Controversy & Litigation practice at Mayer Brown LLP, based in the firm’s Washington DC office. She is an experienced litigator who has handled complex matters at all stages of tax controversy, including IRS audits, administrative appeals, and litigation. Prior to joining Mayer Brown, she was a special trial attorney with the Internal Revenue Service (IRS) Office of Chief Counsel. Rachel has worked on tax matters involving multinational corporations, large partnerships, and high-net-worth individuals, and her experience covers a broad range of subject-matter areas, including transfer pricing, cross-border and treaty issues, valuation disputes, corporate taxation, regulation validity challenges, estate and gift taxation, whistleblower claims, privileges, penalties, and sanctions, spanning industries including pharmaceutical, energy, e-commerce, and financial services.