Zeb Kelley

Robert Z. (Zeb) Kelley is the Chief of Branch 6 in the International Division of the IRS Office of Chief Counsel in Washington, DC.  In this role, he manages a branch of attorneys primarily responsible for legal advice concerning transfer pricing and the characterization and sourcing of digital content transactions for international tax purposes.  

Mr. Kelley has worked for more than 12 years in Branch 6, and was previously Senior Technical Reviewer and Assistant to the Branch Chief.  Prior to the Office of Chief Counsel, he worked as an associate attorney in the Washington, DC offices of Sutherland, Asbill & Brennan LLP and Mayer Brown LLP, specializing in international tax.

• International tax (generally)
• Transfer pricing
• Characterization and sourcing of digital content transactions

• International tax (generally)
• Transfer pricing
• Characterization and sourcing of digital content transactions

• University of Georgia School of Law, JD, 2007
• Davidson College, BA in Political Science, 2004

• Branch Chief (Branch 6), IRS Office of Chief Counsel (International)
• Associate Attorney, Sutherland, Asbill & Brennan
• Associate Attorney, Mayer Brown