Rod Donnelly

Partner

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.

Carleton University, Canada, 1988, Ph.D. (Mathematics)
Memorial University, 1984, M.Eng.
University of London, 1980, B.Sc.
University of Toronto, Canada, 1999, J.D.

California
New York
US Tax Court
US Court of Appeals for the Sixth Circuit
US Court of Appeals for the Eighth Circuit
US Court of Appeals for the Ninth Circuit

Recommended, Tax: US taxes: contentious, The Legal 500 US (2020, 2021, 2023, 2024)

Ranked, Tax, Northern California, Chambers USA (2017, 2020–2024)

Recognized, Tax Law, Palo Alto, The Best Lawyers in America (2018–2023)

Highly Regarded, Tax Controversy, California, International Tax Review's World Tax Guide (2025)

Member, San Francisco & Silicon Valley Tax Firm of the Year, International Tax Review (2018)

Member, Practice Group of the Year, Tax, Law360 (2017)

Leading Advisor, Tax Controversy, International Tax Review’s Tax Controversy Leaders Guide (2017)