A Partner with Jones Day, 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 arising in cross-border transactions, including transfer pricing, tax planning for international transaction flows, structuring international business operations, and resolving tax disputes with the IRS and foreign governments.
Karl has advised multinational corporate groups concerning the restructuring of their U.S. operations. He has also advised U.S.-based companies in structuring their foreign operations, including issues associated with closing foreign operations to achieve a more tax-efficient structure, and the transfer of intangible assets offshore. He has also 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 before the IRS Office of Appeals in resolving a large transfer pricing examination on favorable terms, a large automobile manufacturer in resolving multiple transfer pricing audits, a large foreign high-tech manufacturer in resolving civil and criminal tax issues related to its U.S. operations, a transportation company in resolving U.S. employment tax issues related to employees of its foreign affiliates, and a domestic oil refinery in resolving a very large motor fuels excise tax audit.
Before joining Jones Day, Karl was the acting director of the IRS Advance Pricing Agreement (APA) Program. He also represented the United States before the Organization for Economic Cooperation and Development (OECD). Earlier, Karl was a tax litigator for the United States Department of Justice, and he has extensive experience in tax controversy matters at the administrative level and in federal courts.
Karl has spoken at conferences and seminars on transfer pricing, the APA Program, taxation of intangibles, and other tax issues.
Education:
J.D., Harvard University (1979) magna cum laude
B.A., University of Houston (1976) summa cum laude
Tax Management Portfolios™
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U.S. Income Tax Treaties — Benefits Provided by a Country to Its Own Residents and Citizens (Portfolio 6875)
This Portfolio, 6875 T.M., U.S. Income Tax Treaties — Benefits Provided by a Country to Its Own Residents and Citizens, covers the benefits granted under a bilateral income tax treaty by one of the parties to the treaty to its own residents and citizens.