Karl L.Kellar

Of Counsel

(T) 1.202.879.3824

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.

Experience

Chevron to buy Pasadena Refining System for $350 million from Petrobras America Inc.
Jones Day is advising Chevron U.S.A. Inc., a wholly-owned subsidiary of Chevron Corporation, in its purchase of all of the equity interests of Pasadena Refining System Inc. (“PRSI”) and PRSI Trading, LLC from Petrobras America Inc. for $350 million, subject to adjustments for working capital.

Newell Brands sells The Waddington Group to Novolex for approximately $2.3 billion
Jones Day advised Newell Brands Inc. in its sale of The Waddington Group to Novolex Holdings, a portfolio company of The Carlyle Group, for approximately $2.3 billion in cash.

Monolithic Power settles with U.S. Internal Revenue Service
Jones Day represented Monolithic Power Systems, Inc. in negotiating a settlement with the IRS Appeals Office of a dispute arising from the government's audit of the client's cost-sharing arrangement with its foreign subsidiary.

Large offshore multinational corporation responds successfully to U.S. federal criminal tax investigation
Jones Day represented a large offshore multinational corporation in a federal criminal tax investigation alleging that the company failed to withhold millions of dollars of payroll taxes for hundreds of the company's United States-based employees.

Bridgestone acquires Bandag for $1 billion
Jones Day advised Bridgestone Americas Holding Inc. in its $1.05 billion acquisition of Bandag, Incorporated.

Project Lotus acquires, obtains financing for, and develops luxury mixed-use development in California
Jones Day advised Project Lotus, LLC, a joint venture consisting of Guernsey-based CPC Group (controlled by Christian and Nicholas Candy of Britain) and Iceland-based Kaupthing HS Bank, in the $500 million acquisition of an 8-acre development site at 9900 Wilshire Boulevard in Beverly Hills.

Additional Publications

  • October 31, 2015The US response to the final BEPS Report, Tax Journal
  • 2014U.S. Income Tax Treaties -- Benefits Provided by a Country to Its Own Residents and Citizens, coauthor, 6875 Tax Management Portfolio
  • May 2002Arm's Length Principles - Federal and State Application, coauthor, Practical U.S./Domestic Tax Strategies, vol. 2, no. 5, at 1
  • 2001Application of Section 482 to International Joint Ventures, coauthor, 890 Tax Management Portfolio
  • 1990Economic Accrual of Interest: Tax Court Restrains Administrative Overreach, 49 Tax Notes 1355
  • 1988What the '87 Act Means to Corporations and What They Can Expect in '88, 1 Corporate Taxation 39

Speaking Engagements

  • June 20152015 Tax Executives Institute Region III Conference, Foxwood Resorts and Casino
  • January 2004Current Tax Developments Seminar, Tax Executives Institute
  • December 2002
    December 2003
    Southeast Transfer Pricing Seminar, PricewaterhouseCoopers Annual Conference
  • 2002Taxation of Intangibles Transfers, Conference Board Seminar
  • December 2001Transfer Pricing Seminar, World Trade Education Foundation
  • March 2001Administrative Resolution of Transfer Pricing Disputes, Council for International Tax Education
  • February 2001Transfer Pricing Developments, ABA Section of Taxation panel
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