Tax Notes Celebrates David Rosenbloom’s Contributions to International Tax in New Article

Tax Notes honors David Rosenbloom and his career in international tax as he steps down from the New York University’s prestigious international tax program which he has led for the last 23 years.

Peter Barnes and Scott Michel contributed to the article. To read the article in full, please visit Tax Notes’ website.

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Few practitioners have shaped international tax law, and the people who practice it, with the reach, vision, and sheer longevity of Rosenbloom. That era came to a close in June, when he stepped down from NYU and the program that he helped grow into one of the most desirable in the world.

But Rosenbloom’s entire tax career — one that saw him lead complex treaty renegotiations and testify before numerous legislatures around the world; one that inspired two books honoring his life and contributions to international tax — almost didn’t happen, Rosenbloom told Tax Notes.

“In law school, I hated tax,” he said wryly.

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Rosenbloom also had the right intellectual disposition to take on the task, according to Peter Barnes, Of Counsel at Caplin & Drysdale, and a member of the Tax Notes International’s Council of Eminent Persons.

“Many people who have worked for decades in international tax — or any area of law — begin to coast on their accumulated knowledge. Not David. He devours new court decisions and regulations, and then identifies connections (and disconnections) with other tax rulings,” Barnes said. “And David never presumes that he knows all the answers. He welcomes people pushing back on his views.”

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There’s also a human element to Rosenbloom’s success, Barnes said. “David’s special power is his extraordinary enthusiasm for the intellectual challenges in international tax, and for the many, many people he knows in the profession. I have often remarked that the best group in tax is ‘Friends of David.’ If I am a Friend of David’s and you are as well, then we immediately have a basis for a friendship between us,” Barnes said.

“David remembers the name of almost everyone he has ever met, and he genuinely enjoys catching up on their news and activities. At a large conference, people will come up to David and he remembers their name, their firm, the names of their family, and where David first met the person,” Barnes added. “David is warm and genuine, and so other tax professionals gravitate to him.”

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Scott Michel, a member with Caplin & Drysdale, has worked with Rosenbloom on various matters over the years and said that one of Rosenbloom’s gifts is his sharp ability to foresee tax developments and advise clients on the potential ramifications. This is especially true in the context of U.S. tax enforcement, which experienced a significant shift in the early 2000s when the IRS began to heavily scrutinize U.S. taxpayers stashing money in undeclared offshore accounts. In 2005 Rosenbloom invited Michel to develop and make presentations together before groups of lawyers, bankers, and financial advisers in Zurich and Geneva, Michel said.

“The upshot of our presentation was that it was just a matter of time before the U.S. government would focus on Swiss banks, bankers, and professionals who had helped Americans hide money there,” Michel said. “This was years before the IRS and Justice Department’s Tax Division cracked open Swiss bank secrecy in 2009 with the UBS deferred prosecution agreement, which led to 15 years of active and aggressive enforcement activity in this area.”

“I have always marveled at the degree to which David saw it coming,” he said.

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Not only has Rosenbloom been a mentor, but he has been unafraid to be a student himself.

“David is the kind of person who, when walking the streets of a foreign city, will see an alleyway, or a small street, and want to turn down it just to check it out. To me, his curiosity about a narrow alley in central Hong Kong is a metaphor for his intellect — he’s always curious, always asking questions, and always wants to know what’s around the corner,” Michel said. “Caplin & Drysdale has been so blessed to have him as a colleague and friend.”