Kelly, Stephanie Leigh

Karl Kellar draws on his 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, assisting large public and private companies in structuring international business operations, and assisting companies in 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 assisted U.S.-based companies in structuring their foreign operations, including advice on issues associated with closing foreign operations to achieve a more tax-efficient structure, and the transfer of intangible assets offshore. Among many tax controversy matters Karl has handled, he has recently assisted 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, and a transportation company in resolving U.S. employment tax issues related to employees of its foreign affiliates.

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.