FacultyFaculty/Author Profile
Jonathan R. Zelnik

Jonathan R. Zelnik


Washington, DC, USA

Mr. Zelnik is a principal in the Financial Institutions and Products group of the Firm’s Washington National Tax practice.  He advises clients on tax issues involving debt financings and restructurings, derivative financial contracts, securitizations, hedging transactions, and dealers and traders of securities and commodities.

Before joining KPMG, Mr. Zelnik worked in the IRS’s Office of Chief Counsel, most recently as Senior Counsel to the Chief Counsel, in which role he was primarily responsible for overseeing Counsel’s initiatives to identify, curb, and resolve abusive tax shelters.  He also worked in the Division Counsel (Large & Mid-Size Business) as the legal advisor to the Office of Tax Shelter Analysis and in the Associate Chief Counsel (Financial Institutions & Products) as an Assistant to the Branch Chief and an attorney-advisor.  Mr. Zelnik received the IRS Commissioner’s Award in 2005 and 2001 and the Chief Counsel’s Award in 2006.

 Publications and Speaking Engagements

Co-Editor-In-Chief, Journal of Taxation of Financial Products

“Chomping at the Bit: U.S. Federal Income Taxation of Bitcoin Transactions,” 73 Tax Notes International 353 (Jan. 27, 2014) (co-author).

“IRS Clarifies Meaning of ‘Dealer’ in Securities,” Daily Tax Report (Oct. 10, 2012) (co-author).

“An Overview of the Bank Conformity Election for Bad Debts,” Daily Tax Report (Jan. 13, 2009) (co-author).

“IRS Clears Uncertainty For Over-The-Counter Currency Options,” 117 Tax Notes 1152 (Dec. 27, 2007) (co-authored with Dale Collinson).

Mr. Zelnik has spoken at numerous conferences and firm trainings, including the Bank Tax Institute, the Practicing Law Institute, the Wall Street Tax Association, the American Bar Association, and the DC Bar.


Function and SpecializationFederal income tax aspects of capital market transactions, derivative instruments, and structured financings.

Education, Licenses & Certifications

  • JD, magna cum laude (2nd in class), Loyola Law School in Los Angeles
  • BA, Colby College


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