Tax Advisers - Deloitte

United States
Karl T Walli
Weil, Gotshal & Manges LLP
1501 K Street NW
Suite 100
Washington, DC 20005
US
Tel: (1) 202 682 7177
Fax: (1) 202 857 0940
Email: karl.walli@weil.com
Website: www.weil.com
Karl Walli joined Weil, Gotshal & Manges’ Washington office in November 1996, after
almost 10 years with the Internal Revenue Service and the US Treasury Department.
While in the government, Mr Walli worked primarily in the areas of banking and
financial products, participating in the development of both domestic and international
cases and issues. The taxation of derivative financial products was one of his primary areas
of interest and expertise. He is one of the principal authors of the income tax regulations
on notional principal contracts (§ 1.446-3), was the reviewer on the interest allocation
regulations for foreign corporations (§ 1.882-5), and was a member of the original team
that developed the global dealing regulations. In addition to his work on the global
dealing regulations, Mr Walli worked closely with members of the Internal Revenue
Service’s advance pricing agreement programme, serving as technical advisor for APAs
pertaining to dealers in financial products.
At Weil Gotshal, Mr Walli has worked on a wide variety of domestic and cross-border
transactions, including structured debt instruments, convertible debt and equity, and
derivative financial instruments. He has advised both financial service entities and end
users on tax-advantaged methods for structuring and employing financial instruments,
with an emphasis on cross-border tax arbitrage transactions and tax-efficient hedging
strategies. Mr Walli’s practice also includes the taxation of foreign entities and
investments in the US.
Mr Walli received his BA from the University of Tennessee, a JD from the University of
North Carolina, and a master’s in law and taxation from the College of William and Mary.
316 Guide to the World’s Leading Tax Advisers