David Rosenbloom Comments on Notable Tax Laws and Regulations of 2016
In Law360's midyear report on "5 Notable Tax Laws and Regulations", H. David Rosenbloom discusses the model U.S. income tax convention, which is the starting point for tax treaty negotiations. "By putting it in the model, we're saying we're ready to do this with anyone," Mr. Rosenbloom said in an interview with Law360 earlier this year. "It basically establishes a dispute resolution mechanism that works. It's kind of an amazing thing." It remains to be seen whether some of the measures will be adopted in negotiated treaties or if they can win approval by the Senate. But the inclusion of a mandatory binding arbitration provision should help companies avoid getting whipsawed into double taxation, experts said. To view the complete article, please visit Law360's website (subscription required).