Tax Notes Today Quotes David Rosenbloom: OECD Drafts Call for Domestic Law Solutions to Hybrid Mismatches
H. David Rosenbloom spoke with Tax Notes Today concerning discussion drafts issued by the OECD in response to its base erosion and profit-shifting action plan. The drafts recommend changes to domestic law and the model tax convention to address circumstances in which a hybrid arrangement leads to double deductions or a deduction in a transaction that does not also result in an income inclusion. For the complete article, please visit Tax Notes Today's website (subscription required).
Excerpt taken from the article "OECD Drafts Call for Domestic Law Solutions to Hybrid Mismatches" by David D. Stewart for Tax Notes Today.
H. David Rosenbloom of Caplin & Drysdale told Tax Analysts that the draft on the domestic law recommendations does not alleviate the concerns he had before its release. "Any approach that depends on either international cooperation at the case-by-case level or on really knowing what is going on in another country seems very problematic," Rosenbloom said.