Tax Notes Quotes David Rosenbloom on Tax Reform Open Questions

05.29.2018
Tax Notes

The sheer number of changes made under the Tax Cuts and Jobs Act (P.L. 115-97) have resulted in a number of open questions.

. . .

“To the extent people ask me questions, I do the best I can with the statutory language,” David Rosenbloom of Caplin & Drysdale, Chtd. told Tax Analysts. “And I don’t think Treasury’s got any magic answers to these [questions] either. . . . Everybody’s got to do their best.”

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Long Road Ahead

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“Guidance from God wouldn’t solve these issues,” he said. Treasury might say that its position is, “We interpret black as white for [the] purpose of this section,” Rosenbloom said, and “nobody wants black to be black,” so Treasury will end up taking a position that’s contrary to the law.

Rosenbloom gave the 65 tax treaties and excess credits from previous years as examples of questions Treasury needs to answer. He added that whatever Treasury decides, somebody is “not going to be pleased.” Treasury has an “almost impossible job,” he added.

“This is a business where you live by the word [and] you die by the word,” Rosenbloom said. “If you get your words wrong, that’s a problem.”

For the full article, please visit Tax Notes' website (subscription required).

Excerpt taken from the article "The Business of Tax: ‘We’re Doing Our Best’ May Be New Mantra" by Zoe Sagalow for Tax Notes.

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