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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

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

"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.