Rebecca I. Rosenberg is a member in Caplin & Drysdale’s Washington, D.C. office. She joined the firm at the end of 2000. Ms. Rosenberg's practice focuses on international tax, including foreign tax credit questions, tax treaty matters, the interaction between U.S. and foreign tax laws, and economic substance issues.
From her prior work in all three branches of government, Ms. Rosenberg brings to Caplin & Drysdale’s clients a strong legislative, litigation, and regulatory background. As an attorney advisor and an assistant to the branch chief at the Office of the Associate Chief Counsel (International) at the IRS, Ms. Rosenberg worked extensively in economic substance issues. She was heavily involved in Notice 98-5 (relating to disallowance of certain foreign tax credits) and the IRS’s Tax Court litigation of Compaq Computer Corp. v. Commissioner, 113 T.C. 214 (1999), rev'd 277 F.3d 788 (5th Cir. 2001). She also contributed to the confidential corporate tax shelter registration regulations published under section 6111(d).
Ms. Rosenberg’s expertise extends to foreign tax credit issues as well. She is the principal author of final regulations under section 904(d) and proposed regulations under sections 902 and 904. Ms. Rosenberg also participated in IRS litigation involving a range of foreign tax credit issues, including cases raising treaty arguments.
While at the IRS, Ms. Rosenberg also drafted Notice 2000-20, addressing issues raised by section 987 (and the proposed regulations thereunder) relating to recognition of currency gain and loss. Additionally, she worked on regulations regarding fast-pay preferred stock and FASITs (financial asset securitization investment trusts).
For the four years prior to her tenure at the IRS, Ms. Rosenberg served as an assistant counsel in the Office of the Legislative Counsel of the U.S. House of Representatives. In that capacity, she drafted tax legislation for the members and committees of the House and covered all areas of the Internal Revenue Code of 1986. She participated in drafting meetings on all major tax bills written for the Ways and Means Committee and the Joint Committee on Taxation during this period.
Ms. Rosenberg has been a lecturer at numerous professional meetings at the IRS, the American Bar Association, the D.C. Bar Association, the American Petroleum Institute, and the Tax Executives Institute.