Rod Donnelly

Rod Donnelly focuses his practice on the federal tax aspects of complex international corporate transactions. Representing large multinational corporations, his experience includes complex, high-dollar-value transfer pricing issues, especially with an intangible property component, at both the planning and controversy stages. Rod’s experience also includes FDII, Subpart F, and foreign tax credits, as well as tax-related aspects of manufacturing supply chain and research and development, at both the planning and controversy levels. Rod has drafted for clients many comment letters on Treasury regulations and OECD public discussion drafts and has drafted and submitted briefs dealing with complex tax issues to trial and appellate courts.