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David Rosenbloom's Article Cited on International Tax Portal

January 27, 2018,

H. David Rosenbloom's article “International Aspects of U.S. 'Tax Reform' -- Is This Really Where We Want to Go?“ was cited in a posting by Laurence E. Lipsher on  Below is an excerpt from the posting.  "To view the full posting, please visit's website.

. . .

Ever hear of the Caplin & Drysdale law firm? The[y] are based in Washington, DC and have what I consider to be the best ‘connections' with the IRS of any law firm/lobbyist functioning. If I had a client with a case that even I would not want to handle, I'd refer them to Caplin & Drysdale as the best chance of salvaging their life through IRS negotiations. Thus, I read quite seriously H David Rosen bloom of C&D and his 2 January 2018 article “International Aspects of U.S. 'Tax Reform' -- Is This Really Where We Want to Go?

Referring to the international provisions as well as to a ‘participation exemption system', Rosenbloom states: “The statutory language of the new provisions is dense, and rife with rudderless jargon, bewildering cross-references, and new and unfamiliar terminology. Heroic efforts of staff to explain the provisions in declarative sentences have been helpful to some extent, but the lack of transparency that has consistently characterized the development of the legislation has not.” This is simply an area that needs close scrutiny over the next several months and those of you reading this who own a percentage of a foreign corporation and who are obligated to report this to the Internal Revenue Service should also follow this one as it can potentially upset your proverbial apple cart in a severe manner.


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