Natalie Hoyer Keller
Professional Profile
Natalie Keller's practice focuses on all aspects of tax controversies, including IRS audits, IRS appeals and litigation. She has litigated cases in the U.S. Tax Court, U.S. Court of Federal Claims, U.S. district and bankruptcy courts and U.S. courts of appeal. Natalie also advises U.S. and foreign multinational clients on intercompany transfer pricing planning and compliance, resolution of transfer pricing audits, competent authority and advance pricing agreements. Her transfer pricing experience includes significant cases in the automotive, consumer electronics, medical products and pharmaceutical industries.
Natalie has been recognized as a leading tax practitioner in numerous legal and business publications. Natalie was recognized in the 2011 and 2012 editions of Chambers USA, America's Leading Lawyers for Business in the area of Tax and was "lauded as a 'very bright, straightforward and practical tax counselor'" and "a shrewd negotiator." The 2009-2012 editions of The Legal 500 U.S. featured Natalie for her tax controversy work. She was also included in the 2010-2012 editions of The Best Lawyers in America, an annual referral guide based on more than 2.8 million peer-review surveys.
Representative Matters
General Motors Corp. et al. v. United States, No. 2:07-cv-14464 (E.D. Mich. filed Oct. 19, 2007)
Tenet Healthcare Corp. v. Commissioner, No. 17513-08 (T. Ct. filed July 16, 2008) (stipulated decision Jan. 4, 2011)
Estate of Arthur E. Dahl v. Commissioner, No. 19711-06 (T. Ct. filed Sept. 26, 2006) (stipulated decision Nov. 3, 2008)
Tenet Healthcare Corp. v. Commissioner, No. 5063-06 (T. Ct. filed Mar. 10, 2006) (stipulated decision Mar. 24, 2009)
Quality Stores, Inc. v. United States, 383 B.R. 67 (Bankr. W.D. Mich. 2008)
Alcoa Inc. v. United States, 509 F.3d 173 (3d Cir. 2008)
Anschutz Co. v. Commissioner, No. 21787-04 (T. Ct. filed Nov. 15, 2004) (stipulated decision Mar. 13, 2007)
CCHP, Inc. v. United States, No. 99-158T (Fed. Cl. filed Mar. 23, 1999) (dismissed after settlement Feb. 13, 2007)
Reynolds Metals Co. v. United States, 389 F. Supp.2d 692 (E.D. Va. 2005)
InterTAN Inc. v. Commissioner, 2004 WL 2810188 (5th Cir. 2004)
United Air Lines, Inc. v. United States, 51 Fed. Cl. 722 (2001)
UAL Corp. v. Commissioner, 117 T.C. 7 (2001)
Publications
"Tax Considerations in Structuring International Licensing and Technology Transfer Arrangements," in International Licensing and Technology Transfer: Practice and the Law (Kluwer Law International 2008) (with Russell S. Light)
Martin D. Ginsburg & Jack S. Levin, Mergers, Acquisitions & Buyouts (updated semi-annually) (contributor)
"New Developments in Transfer Pricing," prepared for American Conference Institute Seminar on Transfer Pricing Audits (1999) (with Todd F. Maynes)
Note, "Do You, Elizabeth, Promise to Pay John's Taxes? I Do: A Review of the Innocent Spouse Provisions and a Proposal for Change," 1996 Utah Law Review 1065
Seminars
Speaker, "Transfer Pricing Audit Procedures and Adjustments - Mechanics," National Association for Business Economics (NABE) Transfer Pricing Symposium (2012)
Speaker, "Recent Developments in Tax Controversies: LB&I Initiatives," The Chicago Tax Club (2012)
Speaker, "Current Developments in Competent Authority and APA Proceedings," The Chicago Tax Club (2010)
Speaker, "Ethical Guidelines for Protecting Privilege," Current Tax Developments Affecting Mergers and Acquisitions, presented by Tax Executives Institute, Inc. (2010)
Speaker, "Current Developments in Competent Authority and APA Proceedings," 28th Annual Federal Tax Institute, presented by the Chicago-Kent College of Law (2009)
Speaker, "Debt Modifications and Cancellation of Debt Income Under the Economic Stimulus Legislation," Transaction Structuring in an Economic Downturn: Tax and Legal Considerations of Structuring Transactions in the Current Environment, presented by Tax Executives Institute, Inc. (2009)
Speaker, "Privilege Concerns in Light of FIN 48," International Tax Forum (2007)
Speaker, "Deductibility of Transaction Expenses, Preparing for Common Audit Issues and Handling Due Diligence in an LBO Transaction," Interactions Between Public Companies and Private Equity Funds: Tax and Legal Considerations, presented by Tax Executives Institute, Inc. (2007)
Speaker, "Transfer Pricing -- Methods and Choices," International Tax Forum (2006)
Speaker, "Legal Issues in Starting a Small Business," Chicago Women's Business Development Council (2001)
Courts
United States Court of Appeals for the Third Circuit
United States Court of Appeals for the Fifth Circuit
United States Court of Appeals for the Tenth Circuit
United States Tax Court
United States Court of Federal Claims
United States District Court for the Northern District of Illinois
United States District Court for the Eastern District of Michigan
Supreme Court of Illinois
