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Practice Area(s)

Education

  • J.D., Harvard Law School, 1966, magna cum laude, President, Harvard Law Review, Vol. 79
  • Fullbright, University of Florence, Florence, Italy, 1963
  • A.B., Princeton University, 1962, summa cum laude

Bar and Court Admissions

  • New York
  • District of Columbia
  • U.S. Bankruptcy Court, District of Columbia
  • U.S. District Court, District of Columbia
  • U.S. Supreme Court
  • U.S. Tax Court
  • District of Columbia Court of Appeals

Other Professional Affiliations

Member, International Fiscal Association
Member, U.S. Council for International Business
Member, Board of Directors, Tax Analysts

Government Experience

International Tax Counsel and Director, Office of International Tax Affairs, U.S. Department of Treasury, 1978-1981

Law Clerk, Honorable Abe Fortas, U.S. Supreme Court, 1967-1968

Assistant, Honorable Arthur Goldberg; U.S. Mission to the United Nations, 1966-1967

H. David Rosenbloom

Member, Washington, D.C.
(202) 862-5037
drosenbloom@capdale.com | v-card | PDF

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.

Professional Activities

  • James S. Eustice Visiting Professor of Taxation and Director of International Tax Program, New York University School of Law
  • Lecturer on international taxation at Harvard, Stanford, the University of Pennsylvania, and Columbia Law Schools, and at universities in Sydney, Vienna, Melbourne, Milan, Bergamo, Bologna, Bari, Mexico City, Mainz, Heidelberg, Neuchatel, Lisbon, and Rio de Janeiro
  • Instructed at the University of Pretoria, the Universita del Piemonte Orientale, the Max Planck Institute in Munich, Seoul National University, Leiden University, University of Amsterdam, the Public Finance Training Center in Taipei, and the OECD Multilateral Training Centres for Tax Offices from CIS and Eastern European Countries in Vienna, Ankara, and Budapest

Awards & Rankings

  • Chambers USA, 2008-2013; Senior Statesmen, 2014-Present
  • Chambers Global, 2009-2012; Senior Statesmen, 2016-Present
  • The Legal 500, Hall of Fame, 2018; Recommended, 2010-2014, 2017-Present; Leading Lawyer, 2013-Present
  • The Legal 500, Top-Tier Firm, Tax - US Taxes - Contentious, 2010, 2015-Present
  • The Legal 500, International Tax Team of the Year, 2014-2015
  • Best Lawyers in America, 1989-Present
  • Expert Guides' The Best of the Best, 2009, 2011-2013, 2015
  • Expert Guides' World's Leading Tax Advisers, 2012, 2014
  • Super Lawyers, Washington, D.C., 2008-Present
  • The Washingtonian, Top Lawyers in D.C., 2009, 2011-2012, and 2015
  • Martindale-Hubbell® AV® Preeminent™
  • World Tax, Tax Controversy Leaders, 2020
  • Who's Who Legal, Corporate Tax, Recommeded, 2018-Present; Thought Leader - Corporate Tax 2019-Present

Recent News

Click here for a full list of media coverage.

Recent 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

Click here for a full list of publications.

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