David Rosenbloom Comments on GILTI and TCJA

01.27.2020
Law360 Tax Authority

A regulatory tweak to the international framework of the 2017 tax overhaul, little known outside the tax world, has erupted into a political firestorm as critics claim it amounts to a corporate giveaway from the U.S. Treasury Department.

. . .

“I find it impossible to find electivity in the statute, and I find it hard — not impossible, but very hard — to get to the proposition that the statute excludes high-tax income,” said David Rosenbloom, director of the international tax program at New York University School of Law.

. . .

“They’re trying to make a coherent system, but that’s not their job. That’s Congress’ job,” NYU's Rosenbloom said. “The fact that we don’t have a functioning Congress is no reason for Treasury to do anything unusual.”

David Rosenbloom is also a Member of the International Tax Group at Caplin & Drysdale

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