Zeb Kelley

Zeb Kelley holds the title of Adjunct Professor (part-time) alongside his role as Chief of Branch 6 in the International Division of the IRS Office of Chief Counsel in Washington, DC. His primary responsibilities involve managing legal advice on transfer pricing and digital content transactions for international tax purposes.

• Education: University of Georgia School of Law (JD, 2007); Davidson College (BA in Political Science, 2004).

His expertise and research focus on international tax law, transfer pricing mechanisms, and the characterization/sourcing of digital content transactions. He has over 12 years of experience in Branch 6, previously serving as Senior Technical Reviewer and Assistant to the Branch Chief. Prior to the IRS, he worked at Sutherland, Asbill & Brennan LLP and Mayer Brown LLP as an international tax attorney.