Karl Kellar draws on more than 30 years of experience in the public and private sectors to advise clients on a wide variety of international and domestic tax issues, including transfer pricing, tax planning for international transactions, structuring international operations, and resolving tax disputes with the IRS and foreign governments.
Karl has advised multinational corporate groups concerning the structuring of their U.S. and foreign operations, including closing foreign operations to achieve a more tax-efficient structure, and the transfer of intangible assets offshore. He also has represented several multinational corporations concerning Advance Pricing Agreements and Competent Authority cases. Among many tax controversy matters Karl has handled, he has recently assisted a Silicon Valley high-tech company in resolving a large transfer pricing examination on favorable terms, a large automobile manufacturer in resolving multiple transfer pricing audits, a foreign high-tech manufacturer in resolving U.S. civil and criminal tax issues, a transportation company in resolving U.S. employment tax issues related to its foreign affiliates, and a domestic oil refinery in resolving a large motor fuels excise tax audit.
Before joining Jones Day, Karl was the acting director of the IRS Advance Pricing Agreement (APA) Program and also represented the United States before the OECD. Earlier in his career he was a tax litigator for the United States Department of Justice.
Karl has spoken at conferences and seminars on transfer pricing, the APA Program, taxation of intangibles, and other tax issues. He is coauthor of two Tax Management Portfolios dealing with transfer pricing and tax treaty issues and the Practical Guide to U.S. Transfer Pricing.
The Four Acts of an IRS Controversy: Act I: The Roadmap for Handling a Challenging IRS Examination from a Tax Litigator’s Perspective
Border Adjustments in the Destination-Based Cash-Flow Tax: A Bold Proposal With Unanswered Questions, Bloomberg BNA Daily Tax Report and Bloomberg BNA International Journal
- April 20, 2017
Preparing for a Sea Change: A Conference with the Government and Private Sector to Discuss Comprehensive Tax Reform
- April 27, 2016
International Tax Seminar for Detroit Chapter of Tax Executives Institute
- June 2015
2015 Tax Executives Institute Region III Conference, Foxwood Resorts and Casino
- January 2004
Current Tax Developments Seminar, Tax Executives Institute
Taxation of Intangibles Transfers, Conference Board Seminar
- December 2002
Southeast Transfer Pricing Seminar, PricewaterhouseCoopers Annual Conference
- December 2001
Transfer Pricing Seminar, World Trade Education Foundation
- March 2001
Administrative Resolution of Transfer Pricing Disputes, Council for International Tax Education
- February 2001
Transfer Pricing Developments, ABA Section of Taxation panel
- Harvard University (J.D. magna cum laude 1979); University of Houston (B.A. summa cum laude 1976)
- District of Columbia
- Branch Chief/Acting Director, Advance Pricing Agreement Program, Office of Associate Chief Counsel (International), Internal Revenue Service (1996-2000); Trial Attorney, Tax Division, United States Department of Justice (1979-1984)