Karl handles matters involving all aspects of corporate and partnership tax issues (both for publicly traded and privately held ventures), income tax accounting issues, and tax controversies and litigation in local, state and federal courts. His transactional practice focuses on tax issues in the context of mergers, acquisitions, recapitalizations, dispositions, and other types of business restructurings. Karl also advises clients in matters involving corporate joint ventures, private equity and hedge funds, securities partnerships, and other complex pooling and financing arrangements. Karl’s practice involving tax controversy work includes handling of large case audits and litigation in various federal and state jurisdictions. State and local tax matters he has handled include income, franchise, sales and use, and business license tax controversies in multiple jurisdictions.
Prior to joining Sutherland, Karl was the Washington Tax Group Coordinator for a large national law firm (1986-1997); and a Senior Trial Attorney, Office of Chief Counsel, Internal Revenue Service (1980-1985). He has extensive experience handling tax controversy matters at all administrative government levels (federal, state and local), including before the Internal Revenue Service and United States Treasury and Justice Departments. Karl has litigated cases before the United States Tax Court, the United States Court of Federal Claims, the United States Court of Appeals for the Fifth Circuit and Federal Circuit, and has handled cases in trial and appellate courts in various states including California, New York, Maryland, and Virginia, as well as the District of Columbia. At the IRS, Karl was first chair for major tax litigation and other matters handled by the District Counsel’s office, including evaluation of criminal tax cases, tax refund lawsuits and bankruptcy proceedings.
Karl is a frequent speaker on various tax matters and has written several articles concerning federal tax issues. He has been an Adjunct Professor (Partnership Tax, Corporate Tax, and Tax Accounting) for nearly 20 years at Georgetown University Law Center.