Karen Cate is a Tax Law Specialist in Branch 3 of the Office of Associate Chief Counsel (International) (ACCI). In this capacity she provides advice to the IRS, drafts guidance, and assists with litigation concerning foreign tax credit, source of income, and expense allocation and apportionment matters. Prior to joining the Office of ACCI, Karen was a member of the IRS Treaty Assistance & Interpretation Team (Office of U.S. Competent Authority). In this role, she worked with treaty partners to provide relief of double taxation for a variety of taxpayers. She also represented the IRS in Treasury-led teams negotiating a treaty and served as an IRS delegate to OECD Working Party 1 (Tax Conventions and Related Questions). Before the IRS, Karen was an international tax senior manager at Ernst & Young.