Skip to Main Content

Law360 Quotes David Rosenbloom New Global Tax Rules

July 12, 2021, Law360

Countries are in the final stages of negotiating a corporate tax plan that would reallocate taxing rights among jurisdictions — a policy overhaul that could face roadblocks to implementation, including an existing treaty network that's based on a 100-year-old system.

. . . 

On the global level, there's currently only a tentative agreement setting out general terms, according to David Rosenbloom, a member of Caplin & Drysdale

"Tax laws are very specific," he said. "We've got a long way to go to translate what's been discussed so far into an actual statutory proposal."

. . .

As Rosenbloom at Caplin & Drysdale saw it, "getting the Senate to approve a multilateral treaty would be even harder than getting it to approve a normal bilateral treaty."

. . . 

President Joe Biden's administration only has a fairly limited period of time to come forward with a reconciliation bill for Pillars One and Two, according to Rosenbloom at Caplin & Drysdale. And a reconciliation bill is the only way this measure can be passed under the current dynamics in the Senate, he said.

"I would be astonished if there were an agreement reached on the OECD proposals in time to enter into the reconciliation package with any degree of detail," he said. "The timing on this doesn't seem to me to be conducive to using reconciliation to further anything like Pillar One and Pillar Two."

To view the full article, please visit Law360's website.


About Caplin & Drysdale
Celebrating our 55th Anniversary in 2019, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
New York, NY Office:
295 Madison Avenue
12th Floor
New York, NY 10017


This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
© 2022 Caplin & Drysdale, Chartered
All Rights Reserved.

Related Professionals

Related Practice Area(s)