H. David Rosenbloom is a Member in Caplin & Drysdale's Washington, D.C., office. He rejoined the firm in 1981 after serving as International Tax Counsel and Director of the Office of International Tax Affairs in the US Treasury Department from 1977 to 1981. Mr. Rosenbloom has been recognized as a Senior Statesmen by Chambers USA since 2014 and listed among "Leading Lawyers" by The Legal 500 for his work with clients in International Tax and Tax Controversies.
Services
Mr. Rosenbloom's major areas of practice include international tax planning and controversies, including transfer pricing and advance pricing agreements, the foreign tax credit and subpart F, tax treaty issues and competent authority proceedings, financial products and financial institutions, taxation of all forms of inbound investment, and individual tax compliance in a cross-border context.
Highlights
Mr. Rosenbloom has served as a Tax Policy Advisor for the US Treasury, the OECD, US AID, the International Monetary Fund, and the World Bank in Eastern Europe and the Baltic countries, the former Soviet Union, Senegal, Malawi, and South Africa. He has consulted with and advised foreign governments and international organizations on international tax matters, and served as an expert witness in international tax disputes in the United States, Canada, New Zealand, Norway, and Australia.
He has also written extensively on international and comparative tax topics. His most recent writings discuss the intersection of U.S. tax reform, U.S. tax treaty policy, and the OECD Project on Base Erosion and Profit Shifting.
Mr. Rosenbloom is fluent in French and Italian and has fundamental knowledge of Spanish.
Recent News
- Tax Notes Quotes David Rosenbloom on Coca-Cola's Transfer Pricing Dispute, Tax Notes, February 11, 2021
- David Rosenbloom Comments on Corporate Tax in Corporate Tax Rate Report, WalletHub, October 14, 2020
- Caplin & Drysdale Attorneys Receive Award for Amazon.com v. Commissioner, The ITR Americas Tax Awards, September 25, 2020
- Caplin & Drysdale Earns Top Ranking in 2021 "Best Lawyers in America", U.S. News & World Report, August 20, 2020
- David Rosenbloom Speaks to Tax Notes on Cost Sharing, Tax Notes, July 22, 2020
- 17 Caplin & Drysdale Attorneys Recognized in 2020 Legal 500 Ranking, The Legal 500, July 6, 2020
- David Rosenbloom Comments on Serving as a Clerk to U.S. Supreme Court, Super Lawyers, May 5, 2020
- Chambers USA Recognizes Caplin & Drysdale Attorneys, May 5, 2020
- Caplin & Drysdale D.C. Attorneys are Recognized by Super Lawyers®, Super Lawyers, May 4, 2020
- New York Times Quotes David Rosenbloom on Recent Repeal of Tax Limitations, New York Times, April 24, 2020
- WSJ Quotes David Rosenbloom on International Tax, The Wall Street Journal, April 9, 2020
- David Rosenbloom Speaks to Bloomberg on Treasury Fixing Tax Laws, Bloomberg Law, February 3, 2020
- David Rosenbloom Comments on GILTI and TCJA, Law360 Tax Authority, January 27, 2020
- David Rosenbloom Weighs in on the Use of Data Analytics in Court Cases, Tax Notes, January 23, 2020
- Law360 Quotes David Rosenbloom on Information Sharing, Law360, September 27, 2019
- WSJ Quotes David Rosenbloom: Companies Say They Can Ignore Cost of U.S. Tax Rules, The Wall Street Journal, August 30, 2019
- David Rosenbloom Comments on Amazon Defeating IRS Over Cost-Sharing Rules in Law360, Law360 Tax Authority, August 20, 2019
- Caplin & Drysdale Attorneys Listed as "Best Lawyers In America", August 15, 2019
- David Rosenbloom Speaks to Bloomberg Law on "AbbVie Moves Allergan Profits to U.S. in Partial GOP Tax Law Win", Bloomberg Law, June 26, 2019
- David Rosenbloom Speaks to Law360 on "Closing Gaps In GILTI Opens Up Authority Questions", Law360, June 19, 2019
- David Rosenbloom Speaks to Bloomberg Law on GILTI, Bloomberg Law, June 17, 2019
- The Legal 500 Recognizes 19 Caplin & Drysdale Attorneys, The Legal 500, June 4, 2019
- David Rosenbloom Talks to Bloomberg on Trump's Interest Income, Bloomberg, May 8, 2019
- Caplin & Drysdale Attorneys Recognized Once Again by Chambers USA, Chambers USA, April 25, 2019
- Super Lawyers® Recognizes 22 Caplin & Drysdale Attorneys in D.C., Super Lawyers, April 22, 2019
- David Rosenbloom Comments on Foreign Tax Credit, Tax Notes, March 25, 2019
- David Rosenbloom and Clark Armitage Comment on New Restrictions on Tax Carryovers, Law360, March 22, 2019
- Tax Notes Quotes David Rosenbloom on Implementing Taxation of Foreign Sales of Partnership Interests, Tax Notes, February 19, 2019
- David Rosenbloom Offers Solution to Conflicting Provisions Under FTC Regs, Tax Notes, February 4, 2019
- Who's Who Legal Selects David Rosenbloom and Christopher Rizek as Leaders in Corporate Tax, Who's Who Legal, November 28, 2018
- Peter Barnes and David Rosenbloom Comment on IRS Transfer Pricing Tool, Law360 Tax Authority, November 2, 2018
- David Rosenbloom Talks to POLITICO on UK Digital Services Tax and Its Implications for the U.S., POLITICO, November 1, 2018
- David Rosenbloom Talks to Law360 on Transfer Pricing Issues to be Explored at ABA Conference, Law360, October 2, 2018
- David Rosenbloom Talks to Law360 on Proposed GILTI Regs' Anti-Abuse Rule Seen As Overly Broad, Law360, September 17, 2018
- Worldwide Tax Daily Quotes David Rosenbloom: BEAT Conflict Clouds Future of Pending Tax Treaties, Tax Notes, August 27, 2018
- David Rosenbloom Talks to Law360: Altera Withdrawal Highlights Warring Transfer Pricing Rules, Law360, August 15, 2018
- Caplin & Drysdale Improves Ranking in 2019 "Best Lawyers in America", August 15, 2018
- Bloomberg Law Quotes David Rosenbloom: Tax Loophole Could Let Wealthy Tap 21% Corporate Rate, Bloomberg Law, Daily Tax Report: International, July 12, 2018
- David Rosenbloom Named to The Legal 500's Hall of Fame, The Legal 500, July 10, 2018
- David Rosenbloom and Elizabeth Stevens Submit Amicus Brief to Uphold Decision Favoring Amazon in IRS Transfer Pricing Dispute, Law360, July 9, 2018
- Wall Street Journal Quotes David Rosenbloom: Companies Hope to Beat a New Tax Called the BEAT, The Wall Street Journal, June 26, 2018
- David Rosenbloom Discusses with Tax Notes One Reason Congress Should Revisit the BEAT, Tax Notes, June 18, 2018
- 2018 Legal 500 Distinguishes 18 Caplin & Drysdale Attorneys, Firm Renews "Top-Tier Firm" Ranking for Tax Controversy, The Legal 500, May 31, 2018
- Tax Notes Quotes David Rosenbloom on Tax Reform Open Questions, Tax Notes, May 29, 2018
- David Rosenbloom Quoted by Tax Notes on the Conflict Between GILTI and U.S. Tax Treaties, Tax Notes, May 7, 2018
- Chambers USA Recognizes 10 Caplin & Drysdale Lawyers as "Leaders in Their Fields", Chambers USA, May 3, 2018
- 18 Caplin & Drysdale Attorneys Recognized by Super Lawyers in D.C., April 23, 2018
- Law360 Quotes David Rosenbloom on TCJA and Inversions, Law360, April 16, 2018
- David Rosenbloom Responds to Tax Reform Q&A, WalletHub.com, March 28, 2018
- David Rosenbloom's Article Cited on International Tax Portal, TaxIndiaInternational.com, January 27, 2018
- Peter Barnes and David Rosenbloom Discuss New Tax Law Undermining Treaties and International Policy, Law360, January 9, 2018
- Peter Barnes and David Rosenbloom Discuss Impact of New International Tax System with Law360, Law360, January 1, 2018
- BBC News Quotes David Rosenbloom on Trump's Tax Plans Impact on International Tax, BBC News, December 18, 2017
- David Rosenbloom Comments: Legislation Raises Tax Treaty Concerns for U.S. Multinationals, Daily Tax Report, December 14, 2017
- Law360 Quotes Peter Barnes and David Rosenbloom on International Interest Deductions in Tax Bill, Law360, December 7, 2017
- Law360 Quotes Peter Barnes and David Rosenbloom: Foreign Credits At Risk in Senate Tax Bill, Analysts Say, Law360, November 16, 2017
- Washington Post Quotes David Rosenbloom on Americans with Offshore Interests, The Washington Post, November 14, 2017
- David Rosenbloom Discusses Impact of Cutting Corporate Tax Rate, The Christian Science Monitor, November 8, 2017
- Law360 Quotes David Rosenbloom on Threat to 20% Corporate Tax Rate, Law360, November 8, 2017
- David Rosenbloom Comments on Offshore Tax Havens, Daily Tax Report, November 5, 2017
- David Rosenbloom Comments on Proposed Tax Cuts, TheStreet.com, September 29, 2017
- David Rosenbloom Discusses "Corporate Integration" Plan with Law360, Law360, September 19, 2017
- David Rosenbloom Comments: Delays Fuel Speculation About Regulatory Future, Tax Notes, August 22, 2017
- Caplin & Drysdale Earns Top Ranking in 2018 "Best Lawyers in America", August 15, 2017
- David Rosenbloom Comments on Alternatives to BAT, Forbes, July 28, 2017
- 7 Caplin & Drysdale Lawyers Listed as Leaders in Their Field by Expert Guides, Expert Guides, July 25, 2017
- David Rosenbloom Comments on Trump's Proposed 15% Corporate Tax Rate, Bloomberg Law, June 27, 2017
- 18 Caplin & Drysdale Lawyers Recognized in 2017 Legal 500 Ranking, The Legal 500, June 2, 2017
- Caplin & Drysdale Lawyers Improve Their 2017 Chambers' Rankings, Chambers USA, June 2, 2017
- David Rosenbloom Offers Analysis of Republican Party's Tax Reform Proposal, FiscoOggi, May 31, 2017
- David Rosenbloom Discusses Corporate Repatriation of Profits with Tax Notes, Tax Notes, May 12, 2017
- Caplin & Drysdale Lawyers Listed Among D.C.'s Most Prominent Practitioners, Super Lawyers, April 27, 2017
- BNA Quotes David Rosenbloom: GOP Plan to Bring Back Offshore Cash May Cause Headaches, Bloomberg BNA, April 19, 2017
- Tax Notes Quotes David Rosenbloom: Challenging Outbound Transfers of Intangibles, Tax Notes, April 17, 2017
- Tax Notes Quotes David Rosenbloom: States Consciously Uncoupling From the Cash Flow Tax?, Tax Notes, April 10, 2017
- Tax Notes Quotes David Rosenbloom: The Hexagon of Tax Reform, Tax Notes, April 5, 2017
- Bloomberg TV Interviews David Rosenbloom: Apple Challenges EU Tax Bill: Do They Have a Case?, Bloomberg Technology, December 19, 2016
- David Rosenbloom Comments on Crackdown on Corporate Tax Avoidance, Law360, December 9, 2016
- David Rosenbloom Comments on Americans Paying Apple Millions to Shelter Overseas Profits, WealthManagement.com, December 7, 2016
- David Rosenbloom Comments on EU Tax Probes Prompting Questions About Risk, Tax Management Transfer Pricing Report™, November 17, 2016
- Bloomberg BNA Quotes David Rosenbloom on the Exit Tax, Bloomberg BNA, August 29, 2016
- Best Lawyers in America Lists 18 Caplin & Drysdale Attorneys, U.S. News & World Report, August 15, 2016
- David Rosenbloom Comments on Notable Tax Laws and Regulations of 2016, Law360, July 12, 2016
- David Rosenbloom Comments on EU Starbucks Ruling in Bloomberg BNA, Bloomberg BNA, July 5, 2016
- Bloomberg BNA Quotes David Rosenbloom on Luxembourg and U.S. Working on Treaty Language, Bloomberg BNA, June 23, 2016
- David Rosenbloom Discusses U.S. Uses New Model Treaty Language in Luxembourg Protocol with Tax Notes, Tax Notes, June 23, 2016
- Caplin & Drysdale Recognized for Cutting Edge Advice, The Legal 500, June 16, 2016
- Caplin & Drysdale Listed Among Top Lawyers for Tax, Bankruptcy, Estate Planning and Political Law, Chambers USA, June 1, 2016
- Super Lawyers Recognizes Caplin & Drysdale Lawyers from Several Practice Areas, Super Lawyers, April 26, 2016
- Tax Notes Quotes David Rosenbloom on G-20 Tax Agenda at 2016 NYU/KPMG Tax Lecture, Tax Notes Today, April 19, 2016
- Irish Examiner Quotes David Rosenbloom on Proposed Regulations Aimed at "Earnings Stripping", Irish Examiner, April 12, 2016
- Tax Notes Today Quotes David Rosenbloom on U.S. Model Tax Convention, Tax Notes Today, April 11, 2016
- Law360 Quotes David Rosenbloom on Binding Arbitration Provision in Model Tax Treaty, Law360, February 26, 2016
- Bloomberg Quotes David Rosenbloom on Europe Going After Google and Others for Paying Minimal Taxes, Bloomberg Business, February 18, 2016
- Worldwide Tax Daily Quotes David Rosenbloom on the Revised U.S. Model Tax Convention, Worldwide Tax Daily, February 18, 2016
- Tax Notes Quotes David Rosenbloom on the U.S. Model Tax Treaty, Tax Notes, November 30, 2015
- Washingtonian Names Caplin & Drysdale Attorneys Among Washington's Top Lawyers, November 19, 2015
- David Rosenbloom Comments on BEPS Action 2: The Hybrid Hydra, Tax Notes Today, October 6, 2015
- Bloomberg Quotes David Rosenbloom: Google to Apple Could See Tax Loopholes Curbed in OECD Proposal, Bloomberg Business, October 5, 2015
- H. David Rosenbloom Comments on Questions Remaining on BEPS, U.S. Model Treaty Changes, International Tax Monitor, August 14, 2015
- David Rosenbloom Comments on Altera Corp v. Commissioner and the Arm's Length Standard, International Tax Monitor, July 31, 2015
- David Rosenbloom Comments on U.S.-Vietnam Income Tax Treaty, Worldwide Tax Daily, July 9, 2015
- David Rosenbloom Comments on Baseball-Style Mandatory Binding Arbitration, Tax Notes Today, July 9, 2015
- David Rosenbloom Comments on OECD's BEPS Proposals in Europe, Tax Notes Today, June 8, 2015
- David Rosenbloom Comments on U.S. Model Tax Treaty Proposals, Tax Notes Today, May 22, 2015
- Clients and Peers Distinguish Caplin & Drysdale in Chambers' Rankings, Chambers USA, May 19, 2015
- Bloomberg BNA Quotes David Rosenbloom on Grand Jury Probe in Caterpillar Case, Bloomberg BNA, May 13, 2015
- Bloomberg Quotes David Rosenbloom on 15th Annual Tax Lecture Series, Bloomberg BNA, April 30, 2015
- Super Lawyers Lists Caplin & Drysdale Lawyers, Caplin & Drysdale, April 23, 2015
- David Rosenbloom Named "Best of the Best USA" by Expert Guides, Expert Guides, April 10, 2015
- Worldwide Tax Daily Quotes David Rosenbloom on Arbitration in International Tax Matters, Worldwide Tax Daily, March 31, 2015
- Bloomberg Quotes David Rosenbloom on ‘Dynamic Scoring, Bloomberg BNA, January 22, 2015
- David Rosenbloom Comments on Dynamic Scoring of Tax Measures, The Washington Post, January 11, 2015
- David Rosenbloom Comments on Proposed Improvements to Treaty Dispute Resolution Process, Worldwide Tax Daily, December 19, 2014
- David Rosenbloom Comments on Hong Kong Banks Avoiding FATCA, Worldwide Tax Daily, December 19, 2014
- Caplin & Drysdale Attorneys Featured in Newsweek: How Google and Apple Make Their Taxes Disappear, Newsweek, December 14, 2014
- David Rosenbloom Comments on IRS Releasing Final Regulations on Gain Recognition Agreements, Worldwide Tax Daily, November 19, 2014
- David Rosenbloom Comments on OECD Options for Preventing Artificial Avoidance of PE Status, Worldwide Tax Daily, November 3, 2014
- David Rosenbloom Comments on BEPS Discussion Draft Including Intra-Group Service Fees, Bloomberg BNA, November 3, 2014
- Caplin & Drysdale Lawyers Listed Among World's Leading Tax Advisers, Expert Guides, October 16, 2014
- On the Eve of IFA-Mumbai, Bloomberg Interviews Scott Michel and David Rosenbloom: FATCA Strengthens U.S. Tax Enforcement Hand in India, Daily Tax Report and International Tax Monitor, October 8, 2014
- David Rosenbloom Comments on Domestic FATCA Requirements Possibly Complicating Compliance, International Tax Monitor, August 27, 2014
- Caplin & Drysdale Lawyers Earn Best Lawyers Ranking, August 21, 2014
- David Rosenbloom's FATCA Interview Makes Headlines in Brazil, Jornal do Comércio (Journal of Commerce), August 18, 2014
- Bloomberg BNA Quotes David Rosenbloom and Peter Barnes: Could the White House Act Unilaterally on Taxes?, Bloomberg BNA, July 25, 2014
- Clients and Peers Recommend Caplin & Drysdale in 2014 Legal 500 Ranking, The Legal 500, July 1, 2014
- Caplin & Drysdale Earns Top Honors in 2014 Chambers USA, Chambers USA, May 28, 2014
- David Rosenbloom Comments on Senator Paul's Objections to Tax Treaties, Worldwide Tax Daily, May 9, 2014
- Tax Notes Today Quotes David Rosenbloom: EBay Accepts 'Buy It Now' Tax Price on $9 Billion Repatriation, Tax Notes Today, May 1, 2014
- The Washington Post Lists Caplin & Drysdale Attorneys Among the Top Attorneys in D.C., The Washington Post, April 30, 2014
- NPR Quotes David Rosenbloom: Tax Breaks Could Be Biggest Prize in Pfizer Deal For AstraZeneca, NPR, April 28, 2014
- Tax Analysts Quotes David Rosenbloom: OECD's LOB Approach Needs Refinement, Practitioners Say, Worldwide Tax Daily, April 15, 2014
- Tax Notes Today Quotes David Rosenbloom: OECD Drafts Call for Domestic Law Solutions to Hybrid Mismatches, Tax Notes Today, March 20, 2014
- Executive Leaders Radio Hosts David Rosenbloom, Executive Leaders Radio, February 20, 2014
- Tax Notes Today Quotes David Rosenbloom: Senate Committee Announces Hearing on Pending Tax Treaties, Tax Notes Today, February 20, 2014
- Tax Directors Handbook Recommends Caplin & Drysdale As A Leading Tax Law Firm, Tax Directors Handbook, December 19, 2013
- Washingtonian Recognizes Caplin & Drysdale Attorneys Among Washington's Best Lawyers, Washingtonian Magazine, December 3, 2013
- Patricia Lewis and David Rosenbloom are Listed Among World's Leading Transfer Pricing Advisers, Expert Guides, November 15, 2013
- 19 Caplin & Drysdale Attorneys Achieve Best Lawyers in America Ranking, U.S. News & World Report, October 21, 2013
- Chicago Tribune Quotes David Rosenbloom: IRS Battles Tech Companies Over 2004 Offshore Tax Holiday, Chicago Tribune, July 2, 2013
- Swiss TV Interviews David Rosenbloom: Swiss Parliament Pushes Back on U.S. Banks Deal, Radio Télévision Suisse, June 19, 2013
- David Rosenbloom Testifies Before the Canadian Parliament on Proposed Tax Agreements, Parliament of Canada, House of Commons Standing Committee on Finance, June 17, 2013
- Scott Michel and David Rosenbloom Quoted on Recent U.S. Efforts to Tackle Offshore Tax Evasion, Tax Notes, June 10, 2013
- The Legal 500 Recommends Caplin & Drysdale As a Leading Firm For 2013, The Legal 500, June 3, 2013
- Swiss Media Quotes David Rosenbloom: Swiss Banking Deal Aims to End Tax Dispute with U.S., Tages-Anzeiger, May 30, 2013
- Radio Télévision Suisse Interviews David Rosenbloom About Swiss Banking Agreement with the U.S., Radio Télévision Suisse, May 30, 2013
- 14 Caplin & Drysdale Attorneys Recognized in Chambers USA 2013, Chambers USA, May 29, 2013
- Bloomberg Interviews David Rosenbloom Regarding Apple's Tax Strategy, Bloomberg, May 21, 2013
- David Rosenbloom Comments on Senate Committee Hearing Highlighting Apple's Offshore Accounts, MacNewsWorld, May 17, 2013
- Scott Michel and David Rosenbloom Quoted On the Impact of Offshore Tax Evasion, CardHub.com, May 10, 2013
- Scott Michel and David Rosenbloom Cited in Canadian Report on Tax Evasion, Canadian House of Commons - Report on the Standing Committee on Finance, May 1, 2013
- Super Lawyers Lists Nineteen Caplin & Drysdale Attorneys, Super Lawyers, April 29, 2013
- China Radio International Speaks With David Rosenbloom Regarding Tax Day in the U.S., Beyond Beijing, April 15, 2013
- Scott Michel and David Rosenbloom Comment on Americans with Asian Bank Accounts, Bloomberg, March 25, 2013
- Caplin & Drysdale Lawyers Alert International Athletes to Beware Endorsement Tax Issues, Caplin & Drysdale, March 18, 2013
- PODCAST: IRS Targeting Tax Havens in Singapore and Hong Kong, Accounting Today, March 12, 2013
- H. David Rosenbloom Quoted in Reuters, Chipmaker Altera, U.S. IRS Fight in Cross-Border Tax Case, Reuters, July 24, 2012
- H. David Rosenbloom Discusses FATCA at NYU Law Conference, NYU School of Law News, June 21, 2012
- Chambers and Legal 500 Recognize Caplin & Drysdale in 2012 Top Rankings, Chambers USA / The Legal 500, June 12, 2012
- David Rosenbloom Quoted in Bloomberg, Eaton Expects $160 Million Tax Savings From Ireland Move, Bloomberg, May 21, 2012
- The Washingtonian Lists Eight Caplin & Drysdale Attorneys as Top Lawyers in Washington, Washingtonian Magazine, December 30, 2011
- David Rosenbloom Quoted in The New York Times, Law to Find Tax Evaders Denounced, The New York Times, December 26, 2011
- 2012 Tax Directors Handbook Ranks Caplin & Drysdale as Leading Tax Law Firm, Tax Directors Handbook, December 1, 2011
- David Rosenbloom Quoted in Financial Post, Swiss Banks Near Deal to Disclose Customer Names to U.S., Financial Post, October 24, 2011
- David Rosenbloom Comments in Bloomberg Article, Repatriation Bill to Tax Overseas Profit at 8.75 Percent, Bloomberg, October 6, 2011
- The Best Lawyers in America Ranks 19 Caplin & Drysdale Attorneys as Leaders in Their Field, U.S. News & World Report, September 1, 2011
- Chambers and Legal 500 Recognize Caplin & Drysdale in 2011 Top Rankings, Chambers USA / The Legal 500, June 16, 2011
- Caplin & Drysdale Attorneys Ranked in Legal Media Group's Expert Guides, Expert Guides, March 1, 2011
- H. David Rosenbloom and Patricia G. Lewis Selected in The Best of the Best 2011, Expert Guides, March 1, 2011
- Caplin & Drysdale Attorneys Comment on WikiLeaks' Release of Offshore Account Data, The Wall Street Journal, World Radio Switzerland, The New York Times, Marketplace, February 3, 2011
- David Rosenbloom Comments on Tax Code Reform, Bloomberg, January 27, 2011
- David Rosenbloom Comments on U.S. Companies' Use of Repatriation Strategies to Avoid Taxes, Bloomberg, December 29, 2010
- Tax Directors Handbook Ranks Caplin & Drysdale as Leading Tax Law Firm, Tax Directors Handbook 2011, November 1, 2010
- The Metropolitan Corporate Counsel Interviews David Rosenbloom, The Metropolitan Corporate Counsel, October 4, 2010
- David Rosenbloom Comments on Undeclared Offshore Banking's Shift to the East, September 24, 2010
- David Rosenbloom Comments on IRS's Reorganization for Global Enforcement, The Wall Street Journal, August 6, 2010
- 19 Caplin & Drysdale Attorneys Named Best Lawyers in America, U.S. News & World Report, August 4, 2010
- Chambers USA and Legal 500 Recognize Caplin & Drysdale in 2010 Top Rankings, Chambers USA / The Legal 500, June 15, 2010
- PLC's Which Lawyer? Ranks Caplin & Drysdale's Tax and Private Client Practices in 2010 Top Rankings, Practical Law, June 1, 2010
- David Rosenbloom Comments on International Tax Policy, Insurance News, May 11, 2010
- Caplin & Drysdale Attorneys Comment on the End of the Era of Bank Secrecy, Forexyard, Bloomberg, PRLog, FA Magazine, etc., May 4, 2010
- H. David Rosenbloom Selected in The Best of the Best 2010, Expert Guides, March 1, 2010
- Washingtonian Magazine Lists Six Caplin & Drysdale Attorneys as Top Lawyers in Washington, Washingtonian Magazine, November 1, 2009
- Swiss TV Interviews David Rosenbloom on IRS Crackdown of American Taxpayers With Undeclared Offshore Accounts (French), Le TSR, September 22, 2009
- Something to Aim for, Dealbreaker, September 8, 2009
- Swiss Deal With IRS May Hide Some Tax Cheats, The New York Times, September 7, 2009
- Informant in Tiny Nation Toppled Decades of Banking Secrecy, Sunlight Projects, August 31, 2009
- U.S. Reports Agreement With UBS in Tax Case, The New York Times, August 12, 2009
- Talent in Demand as Transfer Pricing Disputes Gain Attention, A.E. Feldman Blog, June 29, 2009
- Chambers USA 2009 Recognizes Eight Caplin & Drysdale Attorneys as ‘America's Leading Lawyers', Chambers USA, June 15, 2009
- Chip Maker Xilinx Loses Tax Ruling, Wall Street Journal, May 29, 2009
- GlaxoSmithKline, IRS Tangle in Tax Court, Wall Street Journal, May 22, 2009
- Super Lawyers Recognizes Nine Caplin & Drysdale Attorneys in Five Practice Areas, Super Lawyers, March 27, 2009
- PLC's Which Lawyer? Recommended Caplin & Drysdale as Leading in Tax, Practical Law, March 2, 2009
- H. David Rosenbloom and Patricia G. Lewis Selected in The Best of the Best 2009, Expert Guides, March 1, 2009
- Four Caplin & Drysdale Attorneys Recognized as Top Tax Practitioners in the World, Expert Guides, December 1, 2008
Click here for a full list of media coverage.
Speaking Engagements
- Speaker, Treaty Interpretation After BEPS, Max Planck Institute at University of Lausanne, December 19, 2019
- Speaker, Recent International Tax Developments in TCJA, 34th Annual Spring Corporate Tax Day, CBIT Education, Inc., June 24, 2019
- Speaker, U.S. International Tax Reform and It's Global Impact, ATOZ Foundation, May 22, 2019
- Presenter, International Aspects of New U.S. Tax Legislation, University of Louvain and The Brussels Business School Tax Program, May 21, 2019
- Speaker, U.S. Tax Treaty Policy in Light of the MLI, IFA Lunch & Tax Seminar, May 20, 2019
- Speaker, 2017 U.S. Tax Reform and International Business in the U.S., International Tax Talks, Confindustria Emilia, May 17, 2019
- Lecturer, International Tax Law Within the Digital Economy: Is There a War Between the United States and the European Union?, University of Milan, May 15, 2019
- Panelist, Recent International Tax Developments Under TCJA – Section 965, GILTI and BEAT, Committee of Banking Institutions on Taxation (CBIT), 49th Annual Fall Tax Day, October 25, 2018
- Speaker, The Tax Cuts and Jobs Act – Navigating the Sea Change of U.S. International Tax, 18th Annual NYU/KPMG Tax Symposium, April 25, 2018
- Speaker, Brave New World of International Taxation: GILTI, BEAT, and Section 965, 33rd Annual Spring Tax Day of the Committee of Banking Institutions on Taxation, April 23, 2018
- Speaker, U.S. Tax Reform, Confindustria Vicenza, January 12, 2018
- Speaker, U.S. Tax Reform, University of Padova, Master in International Finance and Commerce, January 12, 2018
- Presenter, 2017 U.S. Tax Reform - Main Points and Novelties for Italian Companies Looking to the United States, Confindustria Emilia, January 11, 2018
- Moderator, Brexit and its Tax and Related Impacts on U.S. Multinationals, American Bar Association, Section of Taxation, 2017 May Meeting, May 12, 2017
- Panelist, Debate: What Does "Fairness" Mean and What Role Should it Play in International Tax Policy?, GWU-IRS 29th Annual Institute on Current Issues in International Taxation, December 16, 2016
- Speaker, Taxes: Improving the global framework, German Federal Ministry of Finance, CEPS, November 30, 2016
- Panelist, Fundamental Tax Aspects of the State Aid Controversy, International Tax Institute, November 17, 2016
- Panelist, The New International Tax Landscape: Should U.S. Multinationals Be Worried?, KPMG: After the Election: Tax Overhaul for 2017, November 15, 2016
- Lecturer, O Brave New World — The Looming Rethink of International Taxation in the United States, Klaus Vogal Lecture, September 23, 2016
- Speaker, NYU/KPMG Tax Lecture, New York University School of Law, KPMG, April 19, 2016
- Lecturer, The BEPS Project of the OECD: Implications for a Rational United States, The Norman A. Sugarman Tax Lecture, March 29, 2016
- Speaker, U.S. Tax Developments/BEPS/FATCA, Tax Academy of Singapore, Tax Edge Series: U.S. Tax Developments, September 18, 2015
- Panelist, A Fiscal Revolution, Swiss-American Chamber of Commerce, September 17, 2015
- Panelist, In Pursuit of Tax Research for Growth, SMU-TA Centre for Excellence in Taxation, A New Equilibrium in Tax Competition and Global Tax Co-operation?", September 17, 2015
- The Making of Tax Policy in the U.S., The Chinese University of Hong Kong, Centre for Financial Regulation and Economic Development (CFRED), Tax Law Seminar, September 9, 2015
- Moderator, Offshore Enforcement 2015: Recent Developments and Hot Topics, Caplin & Drysdale, Chartered, September 1, 2015
- Speaker, Actions 8, 9, 10 and 13: Transfer Pricing, VI Congresso Brasileiro de Direito Tributario Internacional, August 20, 2015
- Speaker, Tax Treaties — A Primer, National Association for Business Economics, 2015 Transfer Pricing Symposium, July 21, 2015
- Speaker, The U.S. Reaction to BEPS, Heidelberg University, Mini-Symposium (IFA), July 2, 2015
- Speaker, The U.S. Reaction to BEPS, Heidelberg University, Speech, July 1, 2015
- Speaker, U.S. Perspective on the OECD's BEPS Project, Julius-Maximilians-Universität Würzburg, Speech, June 30, 2015
- Presenter, U.S. Politics in a Time of BEPS, Heinrich-Heine-Universität Düsseldorf, Student Lecture, June 25, 2015
- Presenter, U.S. Politics in a Time of BEPS, Heinrich-Heine-Universität Düsseldorf, Lecture, June 24, 2015
- BEPS and the United States: Implications, Links, Consequences, Max Planck Institute for Tax Law and Public Finance, Lecture, June 22, 2015
- The Base Erosion and Profit Shifting Evolution, Claudio Dematté Research of SDA Bocconi School of Management, Global BEPS Conference, May 26, 2015
- Debate Panel: "Is the U.S. International Tax System Really Broken?", New York Law School and KPMG LLP, 15th Annual Lecture Series on Current Issues in Taxation, April 21, 2015
- Faculty, Tax Planning in the U.S., WU/Institute for Austrian and International Tax Law and Akademie der Wirtschaftstreuhänder GmbH, LL.M. Program in International Tax Law, March 20, 2015
- Speaker, The U.S. Reaction to BEPS, MASIT International Tax Policy Update 2015, Tax Rulings and EU State Aid Rules/U.S. and UK Perspective on BEPS, February 3, 2015
- Speaker, The Implications of FATCA in Switzerland, University of Geneva, Tax Law Day, February 2, 2015
- Presenter, Qualification of Arbitrators: Procedural Rules and The Role of Taxpayers, Vienna University of Economics and Business, International Arbitration in Tax Matters: Taking the Debate, January 19, 2015
- Speaker, Tax Treaty Policy of the United States, The Instituto Tecnológico Autónomo de México (ITAM), November 21, 2014
- Speaker, U.S. Tax Law, Copenhagen Business School, Tax Conference: Qualification and Withholding Taxes on Dividends, November 12, 2014
- Speaker, U.S. Model Treaty on Dividends, Copenhagen Business School, Tax Conference: Qualification and Withholding Taxes on Dividends, November 12, 2014
- Speaker, U.S. Taxation of Foreign Corporations Business Profits: and Other Code and Treaty Developments, Bloomberg BNA, Tax Treaties: Recent Developments and Emerging Issues, November 5, 2014
- Panelist, Offshore Enforcement 2014: Recent Developments and Hot Topics, Caplin & Drysdale, Chartered, October 13, 2014
- Speaker, International Treaties to Avoid Double Taxation and Exchange of Information: Current Situation Between USA and Prospects for the Future, First International Forum on Taxation, The National Institute of Legal Studies and Business, August 22, 2014
- Speaker, International Taxation: A Curent View from the U.S., Pontifícia Universidade Católica do Rio Grande do Sul (PUCRS), August 22, 2014
- Speaker, Major Issues in Cross-Border Taxation, Making of U.S. Tax Policy, ITP, New York Unviersity, August 21, 2014
- Speaker, Guest Speaker, International Fiscal Association (IFA) and Canadian Tax Foundation (CTF), Treaty Shopping: Anticipating Developments in Canada and Internationally, February 5, 2014
- Speaker, What Should Finance Do About Treaty Shopping?, International Fiscal Association (IFA) and Canadian Tax Foundation (CTF), Treaty Shopping: Anticipating Developments in Canada and Internationally, February 5, 2014
- "What Should Finance Do About Treaty Shopping?", February 3, 2014
- David Rosenbloom to Speak at Legal Affairs Group Luncheon, January 15, 2014
- Scott Michel and David Rosenbloom to Speak at IFA Copenhagen 2013, August 26, 2013
- H. David Rosenbloom Presents Lecture Series in Italy, May 6, 2013
- David Rosenbloom Speaks at Tax Lecture Series on Tax Planning for U.S Inbound Investment, April 18, 2013
- H. David Rosenbloom to Speak at the 2013 International Taxation Conference, March 1, 2013
- H. David Rosenbloom to Appear before the Standing Committee on Finance, February 7, 2013
- H. David Rosenbloom to Speak at 75th Anniversary of the International Fiscal Association, February 2, 2013
- H. David Rosenbloom to Speak at the University of London, January 16, 2013
- H. David Rosenbloom to Speak at the Wall Street Tax Association, November 26, 2012
- Scott D. Michel & H. David Rosenbloom to Speak at ABA Section of Taxation's Conference on International Tax Enforcement, November 8, 2012
- H. David Rosenbloom to Speak at Mumbai Law Firm, October 30, 2012
- H. David Rosenbloom to Speak at NYU-ACTL US International Taxation Conference: Issues For The Years Ahead, October 23, 2012
- H. David Rosenbloom to Speak at Vienna University of Economics and Business Tax Governance Conference, September 20, 2012
- H. David Rosenbloom to Chair the NYU School of Law and the Amsterdam Centre for Tax Law Conference FATCA From a US and EU Perspective, June 21, 2012
- H. David Rosenbloom Speaks About The Vodafone Decision Impact on US-India Investment Strategies in NYC, January 25, 2012
- International Tax Policy: A Current View from the United States, August 3, 2011
- Panelist, David Rosenbloom to Speak on Competent Authority Panel, George Washington University & The Internal Revenue Service, 23rd Annual Institute on Current Issues in International Taxation, December 9, 2010
- Speaker, The UBS Saga and Its aftermath: Aspects of International Tax Compliance, Tax Executives Institute, Inc., Virginia Chapter Meeting, November 18, 2010
- Tax in the Spotlight: Governments and Tax Directors under Pressure, September 29, 2010
- Taxation and Human Rights in Europe and the World, September 16, 2010
- The Foreign Account Tax Compliance Act in 2010 Explored, August 5, 2010
- International Tax Issues Facing U.S. Taxpayers With Foreign Accounts and Their Financial Institutions, March 18, 2010
- Panelist, Global Trends in Tax Reform and How These Might Impact Developments in U.S. International Taxation, Federal Bar Association, March 5, 2010
- Cross-Border Tax Arbitrage: The Good, The Bad and The Ugly, November 10, 2006
Click here for a full list of speaking engagements.
Recent Publications
- "Coke Concentrate: A Recipe for Understanding the IRS's Biggest Win in 40 Years,"
with J. Clark Armitage, Heather D. Schafroth, and Elizabeth J. Stevens, IBFD International Transfer Pricing Journal, January 28, 2021
- "The Adams Challenge Tax Court Decision Reinforces the Benefits of Foreign Taxpayers Filing Protective U.S. Returns,"
with J. Clark Armitage, Dianne C. Mehany, and James E. Salles, Caplin & Drysdale Client Alert, January 26, 2021
- "IRS Wins Big in The Coca-Cola Company & Subs. v. Commissioner,"
with J. Clark Armitage, Kirsten Burmester, Heather D. Schafroth, and Elizabeth J. Stevens, Caplin & Drysdale Client Alert, November 23, 2020
- "A Seat at the Table: Thought Leaders Discuss OECD's Plans on Digital Economy Taxation,"
with Peter A. Barnes, Tax Notes Federal, June 15, 2020
- "COVID-19 and Tax Law: A Current View from the United States,"
with Peter A. Barnes, Belt and Road Initiative Tax Journal, June 3, 2020
- "CARES Act Offers Income Tax Relief for Business,"
with J. Clark Armitage, Jonathan S. Brenner, Kirsten Burmester, and James E. Salles, Caplin & Drysdale Client Alert, March 27, 2020
- "VIEWPOINT: Digital Services Taxes: How Did We Get Into This Mess?,"
with Peter A. Barnes, Tax Notes Federal, March 23, 2020
- "VIEWPOINT: The U.S. Foreign Tax Credit Limitation: How It Works, Why It Matters,"
Tax Notes Federal, March 9, 2020
- "Interpreting the TCJA: Standing Up (With Reservations) for Treasury,"
Tax Notes Federal Letters to the Editor, January 27, 2020
- "Go BIG! How to Build a Tax Effort Worthy of the Belt and Road Initiative,"
with Peter A. Barnes, Journal of International Taxation in China, December 11, 2019
- "OECD Announces a Public Consultation for Global Minimum Tax Rules,"
with J. Clark Armitage, Kirsten Burmester, and Elizabeth J. Stevens, Caplin & Drysdale Client Alert, November 25, 2019
- "U.S. Tax Policy and Cross-Border Investments in 2019: The General Picture,"
Rivista di Diritto Tributario Internazionale - International Tax Law Review, November 12, 2019
- "An OECD "Unified Approach" to Addressing the Challenges of the Digital Economy,"
with J. Clark Armitage, Kirsten Burmester, and Elizabeth J. Stevens, Caplin & Drysdale Client Alert, November 4, 2019
- "COMMENTARY & ANALYSIS: The TCJA and the Treaties,"
with Fadi Shaheen, Tax Notes International Magazine, September 9, 2019
- "Proposed Regulations Under Section 956,"
with Jonathan S. Brenner and Josiah Child, Caplin & Drysdale Client Alert, November 6, 2018
- "COMMENTARY & ANALYSIS: The BEAT and the Treaties,"
with Fadi Shaheen, Tax Notes International Magazine, October 15, 2018
- "Kumquat: The U.S. International Tax Issues,"
Tax Notes International Magazine, June 25, 2018
- "GILTI Pleasures,"
with Elizabeth J. Stevens, Tax Notes International Magazine, February 12, 2018
- "U.S. Plays Lone Ranger on International Tax to Its Detriment,"
with Peter A. Barnes, The Hill Op-Ed, January 19, 2018
- "International Aspects of U.S. 'Tax Reform' -- Is This Really Where We Want to Go?,"
International Tax Report, January 2, 2018
- "David Rosenbloom Comments on Tax Bills' Impact on Earnings of U.S.-Owned Foreign Corporations,"
The Washington Post Op-Ed, December 3, 2017
- "Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets,"
with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Kirsten Burmester, Caplin & Drysdale Client Alert, November 6, 2017
- "Low-Tax Texas Should Pay Its Fair Share of Harvey Costs,"
with Peter A. Barnes, The Washington Post Op-Ed, September 6, 2017
- "Foreword for Asian Voices: BEPS and Beyond,"
International Bureau of Fiscal Documentation (IBFD), July 1, 2017
- "U.S. Corporate Tax Reform and Wallace Stevens,"
with Peter A. Barnes, Tax Notes, May 30, 2017
- "The Destination-Based Cash Flow Tax Is a VAT?,"
with Peter A. Barnes, Tax Notes, March 29, 2017
- "U.S. Corporate Tax Reform and Jean-Paul Sartre,"
with Peter A. Barnes, Tax Notes, March 1, 2017
- "The U.S. Must Avoid This Untested Approach To International Taxes,"
with Peter A. Barnes, The Hill Op-Ed, January 24, 2017
- "The U.S. Country-by-Country Reporting Regulations: A Synopsis,"
Global Taxation, October 1, 2016
- "Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership,"
with Scott D. Michel, Kirsten Burmester, and J. Clark Armitage, Caplin & Drysdale Client Alert, April 5, 2016
- "The Ethical Limits of Tax Planning,"
with J. Clark Armitage and Peter A. Barnes, Trusts and Trustees, January 6, 2016
- "Derivative Benefits and Equivalent Beneficiaries - What Are We Talking About? Part II,"
International Tax Report, December 10, 2015
- "Derivative Benefits and Equivalent Beneficiaries - What Are We Talking About? Part I,"
International Tax Report, November 5, 2015
- "Response to Final OECD BEPS Tome,"
with Patricia Gimbel Lewis, J. Clark Armitage, and Peter A. Barnes, International Law Office, October 30, 2015
- "The Final OECD BEPS Tome Has Arrived,"
with Patricia Gimbel Lewis, J. Clark Armitage, Peter A. Barnes, and Neal M. Kochman, Caplin & Drysdale Client Alert, October 8, 2015
- "Transfer Pricing Audits: Flipping the Tested Party,"
with J. Clark Armitage and Peter A. Barnes, International Law Office, August 28, 2015
- "Transfer Pricing Audits: Flipping the Tested Party,"
with Peter A. Barnes, J. Clark Armitage, Neal M. Kochman, and Patricia Gimbel Lewis, Wolters Kluwer, August 27, 2015
- "IRS Releases Guidelines for Examining CFC Transactions,"
with J. Clark Armitage and Peter A. Barnes, International Law Office, August 21, 2015
- "Transfer Pricing Audits: Flipping the Tested Party,"
with Peter A. Barnes, J. Clark Armitage, Neal M. Kochman, and Mark D. Allison, Caplin & Drysdale Client Alert, August 13, 2015
- "IRS Releases Guidelines for Examining CFC Transactions,"
with Peter A. Barnes, J. Clark Armitage, Neal M. Kochman, and Mark D. Allison, Caplin & Drysdale Client Alert, July 29, 2015
- "The Intersection of U.S. Tax Treaty Policy, Tax Reform, and BEPS,"
International Law Office, July 24, 2015
- "Treasury Proposes Significant Changes to Model Tax Treaty,"
with J. Clark Armitage, Peter A. Barnes, and Neal M. Kochman, International Law Office, June 12, 2015
- "Treasury Proposes Significant Changes to U.S. Model Tax Treaty,"
with J. Clark Armitage, Peter A. Barnes, Neal M. Kochman, and Patricia Gimbel Lewis, Caplin & Drysdale Client Alert, May 26, 2015
- "Reflections on the Intersection of U.S. Tax Treaty Policy, U.S. Tax Reform, and BEPS,"
Tax Notes International, May 25, 2015
- "Will the Rush to Invert Spur Corporate Tax Reform? A Conversation,"
Tax Notes International, December 15, 2014
- "Surprise! Your Foreign Tax Credit Is Not Allowed Under Section 901(I),"
with Sae Jin Yoon, Tax Notes International, January 14, 2014
- "Professional Golfer Sergio Garcia to Owe More Taxes on Endorsement Income,"
with Mark D. Allison, Caplin & Drysdale Client Alert, March 15, 2013
- "Article from Tax Analysts, Switzerland and the U.S.: What We Have Here is a Failure to Communicate,"
Tax Analysts, by H. David Rosenbloom, June 4, 2012
- "FATCA & Foreign Bank Accounts: Has the U.S. Overreacted?,"
with Scott D. Michel, Tax Analysts, May 31, 2011
- "IRS Seeks Names of U.S. Account Holders at HSBC (India),"
with Scott D. Michel, Taxmann-The Tax & Corporate laws of India-International Tax, April 18, 2011
- "Indictment of Offshore Account Holder Portends a New Round of Aggressive Enforcement,"
with Scott D. Michel, International Taxation, February 1, 2011
- "The Foreign Account Tax Compliance Act and Notice 2010-60,"
International Taxation, December 1, 2010
- "More and More Transfer Pricing Enforcement in Store!,"
with Neal M. Kochman and Patricia Gimbel Lewis, Caplin & Drysdale Client Alert, August 6, 2010
- "The Foreign Account Tax Compliance Act,"
May 11, 2010
- "IRS Launches New "Transfer Pricing Practice" -- Pilot Program Will Select Audit Cases for Scrutiny,"
with Neal M. Kochman and Patricia Gimbel Lewis, Caplin & Drysdale Client Alert, May 5, 2010
- "The New U.S.-Italy Treaty: A U.S. Perspective,"
with Kirsten Burmester, Diritto e Pratica Tributaria Internazionale, August 1, 2009
- "Resolución de Conflictos en Material Fiscal (in Spanish),"
Revista - Instituto Colombiano de Derecho Tributario, May 10, 2009
- "Time for a Change: Toward a New Korea-U.S. Income Tax Treaty,"
Tax Notes International, April 20, 2009
- "From Arbitration to Zero Withholding: A Primer on the U.S.-Canada Treaty Protocol,"
Tax Notes International, August 20, 2008
- "Deductions for Non-U.S. Persons Under U.S. Income Tax Laws,"
with Kirsten Burmester, International Tax Planning, March 1, 2008
- "Self-Created Transfer Pricing Adjustments,"
Tax Notes International, June 4, 2007
- "Tax Alert,"
with Neal M. Kochman, Caplin & Drysdale, June 15, 2005
- "TNI Interview: H. David Rosenbloom,"
Tax Notes International, May 10, 2004
- "Banes of an Income Tax: Legal Fictions, Elections, Hypothetical Determinations, Related Party Debt*,"
The Sydney Law Review, March 30, 2004
- "Think About Subpart F: The Domestic Base Company,"
The Tax Magazine, March 15, 2004
- "Banes of an Income Tax: Legal Fictions, Elections, Hypothetical Determinations, And Related Party Debt,"
Tax Notes International, December 31, 2003
- "Why Not Des Moines? A Fresh Entry in the Subpart F Debate,"
Tax Notes International, December 15, 2003
- "Testimony of David Rosenbloom Before the U.S. Senate Committee on Finance,"
Committee on Finance, United States Senate, July 15, 2003
- "Deconstructing Section 905(c): An Examination of The Redetermination Rules After TRA 1997,"
with Neal M. Kochman, Tax Notes International, April 1, 2002
- "Taxes Covered By §960(a)(3),"
Tax Management International Journal, February 8, 2002
- "From the Bottom Up: Taxing the Income of Foreign Controlled Corporations,"
Brooklyn Journal of International Law, September 1, 2001
- "Arbitrage and Transfer Pricing Paper,"
Report of Proceedings of the First World Tax Conference: Taxes Without Borders, October 1, 2000
- "U.S. Proposed Global Trading Regs: Preliminary Questions Regarding Application,"
Tax Notes International, May 23, 1998
- "Commentary: Caplin & Drysdale Blasts Proposed Foreign Tax Credit Regs,"
Tax Notes International, May 5, 1997
Click here for a full list of publications.