Natalie Hoyer Keller

Partner Tax Disputes


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 proceedings 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 2011–2024 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 2009–2023 editions of The Legal 500 United States featured Natalie for her tax controversy work. She was also included in the 2010–2023 editions of The Best Lawyers in America, an annual referral guide based on more than 2.8 million peer-review surveys, and was recognized for her tax law work by Best Lawyers, Spring 2017 Business Edition, “Women In The Law.”


Thought Leadership


"Tax Considerations in Structuring International Licensing and Technology Transfer Arrangements," in International Licensing and Technology Transfer: Practice and the Law (Kluwer Law International 2008) (updated periodically) (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


Speaker, “Valuation Enforcement Cases - SEC and IRS Valuation Controversies,” American Society of Appraisers International Conference (2020) 

Speaker, "Non-Tax Cases that Are Transfer Pricing Focused," National Association for Business Economics (NABE) Transfer Pricing Symposium (2014)

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)


Chambers USA: America's Leading Lawyers for Business, 2011–2024

The Legal 500: The Clients Guide to the U.S. Legal Profession, 2009–2023 (Tax Controversy) 

The Best Lawyers in America, 2010–2023

Received Montana Society of CPAs Gold Medal Award, 1992


Admissions & Qualifications

  • 1997Illinois


  • University of Utah, S.J. Quinney College of LawJ.D.1997

    Order of the Coif

    Editor-in-Chief, Utah Law Review

    Outstanding Achievement Awards in Corporate Tax, Pension & Employee Benefits, Estate Planning, Constitutional Law and Legal Writing & Research

    CALI Awards in Trusts & Estates, Securities Regulation and Legal Profession

  • University of MontanaB.S., Business Administrationwith High Honors1992