James Kelly is a Tax Controversy associate in Mayer Brown’s New York office. Since joining the firm in 2012, James has represented taxpayers in federal tax controversies involving major corporate tax matters. James’s litigation experience includes trial work in the United States Tax Court as well as matters in the United States District Courts.
His practice has focused in particular on transfer pricing and privilege issues. He has also represented multinational clients in negotiations for bilateral advance pricing agreements (APAs).
James has actively participated in the firm’s pro bono efforts, performing corporate and tax planning to establish several non-profit organizations and advise them on an ongoing basis. James received his JD magna cum laude from the University of Michigan Law School where he was Order of the Coif and the recipient of the Richard Katcher Senior Tax Prize.
Mayer Brown was recently named Tax Controversy Team of the Year for the second consecutive year in the Legal 500 United States Awards. “Mayer Brown is ‘among the best’ and fields a large team…dedicated exclusively to tax controversy and transfer pricing,” said Legal 500 and its sources in the US edition. The firm is “regularly seen in the most high-profile controversy cases before the US Tax Court” and produced “yet another impressive run of work” in 2014.
- The University of Michigan Law School, JD, magna cum laude
- New York University, BS
- District of Columbia
- New York
- US Tax Court
- Tribune Media Company F.K.A. Tribune Company & Affiliates v. Commissioner of Internal Revenue, T.C. Docket No. 20940-16 (tax treatment of leveraged partnership transaction).
- Guidant LLC, et. al., v. Commissioner of Internal Revenue, T.C. Docket Nos. 5989-11, 5990-11, 10985-11, 26876-11, 5501-12, 5502-12 (IRC § 482 reallocations).
- Eaton Corporation v. Commissioner of Internal Revenue, T.C. Memo. 2017-147 (finding after trial that the IRS’s cancellation of Advance Pricing Agreements was an abuse of discretion).
- United States v. Eaton Corporation, Nos. 1:13-mc-102, 1:13-mc-111, 1:13-mc-112 (N.D. Ohio 2014); 2:13-cv-01825 (W.D. Pa. 2014); 3:13-cv-01956 (D.P.R. 2014) (summons enforcement litigation).
- Eaton Corporation v. Commissioner, 140 T.C. 410 (2013) (abuse of discretion standard applies to advanced pricing agreement cancellation).
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