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Allison, Mark D.
Armitage, J. Clark
Barnes, Peter A.
Barzell, Dustin J.
Biss, Meghan R.
Black, Jonathan R.
Brenner, Jonathan S.
Burmester, Kirsten
Caplin (1916 - 2019), Mortimer M.
Carney, Leila D.
Carney, Robert T.
Child, Josiah
Crawford , Monty
Davis, Kevin M.
Drysdale (1924 - 2018), Douglas D.
Eisenstat, Benjamin Z.
Elber, Niles A.
Esman, Aaron M.
Fournier, William D.
Goon , Michael
Hannes, Steven P.
Jaramillo, Victor A.
Kaufman, Beth Shapiro
Kelleher, Leslie M.
Klimon, William M.
Kochman, Neal M.
Koski, Jeanna Rickards
Langley, Ann Weber
Laughlin, Felix B.
Leon, Amanda M.
Lewis, Patricia Gimbel
Liesemer, Jeffrey A.
Maclay, Kevin C.
Marshall, Olivia N.
Matthews, Mark E.
McMillan, Ann C.
Mehany, Dianne C.
Michel, Scott D.
Miller, Nathaniel R.
Morgan, Bryson B.
Muncey , Meghan E.
Namorato, Cono R.
O'Brien, Anne J.
O'Connor, George M.
Partain, Rachel L.
Phillips, Todd E.
Polk, Shauna
Potter, Trevor
Raafi, Shahriar M. (Shah)
Rizek, Christopher S.
Rosenbaum, Daniel B.
Rosenbloom, H. David
Ruchelman, Charles M.
Salles, James E.
Sanderson, Matthew T.
Schafroth, Heather D.
Schick, Sharon H.
Scott, Leighanne
Self , Lucas H.
Sharkey, Ross R.
Skillman, Richard W.
Slocombe, Walter B.
Smiley, Stafford
Smith, Lauren G.
Stevens, Elizabeth J.
Varley, Douglas N.
Want, Sharon P.
Wehner, James P.
Wernke, Megan E.
Yoon, Sae Jin
Zendeh, Katy
Ziering, Zhanna A.
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Business, Investment & Transactional Tax Alert
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By Attorney:
H. David Rosenbloom
Alerts
Tax Alert
The
Adams Challenge
Tax Court Decision Reinforces the Benefits of Foreign Taxpayers Filing Protective U.S. Returns
January 26, 2021
International Tax Alert
IRS Wins Big in
The Coca-Cola Company & Subs. v. Commissioner
November 23, 2020
Tax Alert
CARES Act Offers Income Tax Relief for Business
March 27, 2020
International Tax Alert
OECD Announces a Public Consultation for Global Minimum Tax Rules
November 25, 2019
International Tax Alert
An OECD "Unified Approach" to Addressing the Challenges of the Digital Economy
November 4, 2019
Business, Investment & Transactional Tax Alert
Proposed Regulations Under Section 956
November 6, 2018
Tax Alert
Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets
November 6, 2017
Tax Alert
Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership
April 5, 2016
International Tax Alert
The Final OECD BEPS Tome Has Arrived
October 8, 2015
International Tax Alert
Transfer Pricing Audits: Flipping the Tested Party
August 13, 2015
International Tax Alert
IRS Releases Guidelines for Examining CFC Transactions
July 29, 2015
International Tax Alert
Treasury Proposes Significant Changes to U.S. Model Tax Treaty
May 26, 2015
International Tax Alert
Professional Golfer Sergio Garcia to Owe More Taxes on Endorsement Income
March 15, 2013
International Tax Alert
More and More Transfer Pricing Enforcement in Store!
August 6, 2010
International Tax Alert
IRS Launches New "Transfer Pricing Practice" -- Pilot Program Will Select Audit Cases for Scrutiny
May 5, 2010
Published Articles & Books
Coke Concentrate: A Recipe for Understanding the IRS's Biggest Win in 40 Years
IBFD International Transfer Pricing Journal
January 28, 2021
A Seat at the Table: Thought Leaders Discuss OECD's Plans on Digital Economy Taxation
Tax Notes Federal
June 15, 2020
COVID-19 and Tax Law: A Current View from the United States
Belt and Road Initiative Tax Journal
June 3, 2020
VIEWPOINT: Digital Services Taxes: How Did We Get Into This Mess?
Tax Notes Federal
March 23, 2020
VIEWPOINT: The U.S. Foreign Tax Credit Limitation: How It Works, Why It Matters
Tax Notes Federal
March 9, 2020
Interpreting the TCJA: Standing Up (With Reservations) for Treasury
Tax Notes Federal Letters to the Editor
January 27, 2020
Go BIG! How to Build a Tax Effort Worthy of the Belt and Road Initiative
Journal of International Taxation in China
December 11, 2019
U.S. Tax Policy and Cross-Border Investments in 2019: The General Picture
Rivista di Diritto Tributario Internazionale - International Tax Law Review
November 12, 2019
COMMENTARY & ANALYSIS: The TCJA and the Treaties
Tax Notes International Magazine
September 9, 2019
COMMENTARY & ANALYSIS: The BEAT and the Treaties
Tax Notes International Magazine
October 15, 2018
Kumquat: The U.S. International Tax Issues
Tax Notes International Magazine
June 25, 2018
GILTI Pleasures
Tax Notes International Magazine
February 12, 2018
U.S. Plays Lone Ranger on International Tax to Its Detriment
The Hill Op-Ed
January 19, 2018
International Aspects of U.S. 'Tax Reform' -- Is This Really Where We Want to Go?
International Tax Report
January 2, 2018
David Rosenbloom Comments on Tax Bills' Impact on Earnings of U.S.-Owned Foreign Corporations
The Washington Post Op-Ed
December 3, 2017
Low-Tax Texas Should Pay Its Fair Share of Harvey Costs
The Washington Post Op-Ed
September 6, 2017
Foreword for Asian Voices: BEPS and Beyond
International Bureau of Fiscal Documentation (IBFD)
July 1, 2017
U.S. Corporate Tax Reform and Wallace Stevens
Tax Notes
May 30, 2017
The Destination-Based Cash Flow Tax Is a VAT?
Tax Notes
March 29, 2017
U.S. Corporate Tax Reform and Jean-Paul Sartre
Tax Notes
March 1, 2017
The U.S. Must Avoid This Untested Approach To International Taxes
The Hill Op-Ed
January 24, 2017
The U.S. Country-by-Country Reporting Regulations: A Synopsis
Global Taxation
October 1, 2016
The Ethical Limits of Tax Planning
Trusts and Trustees
January 6, 2016
Derivative Benefits and Equivalent Beneficiaries - What Are We Talking About? Part II
International Tax Report
December 10, 2015
Derivative Benefits and Equivalent Beneficiaries - What Are We Talking About? Part I
International Tax Report
November 5, 2015
Response to Final OECD BEPS Tome
International Law Office
October 30, 2015
Transfer Pricing Audits: Flipping the Tested Party
International Law Office
August 28, 2015
Transfer Pricing Audits: Flipping the Tested Party
Wolters Kluwer
August 27, 2015
IRS Releases Guidelines for Examining CFC Transactions
International Law Office
August 21, 2015
The Intersection of U.S. Tax Treaty Policy, Tax Reform, and BEPS
International Law Office
July 24, 2015
Treasury Proposes Significant Changes to Model Tax Treaty
International Law Office
June 12, 2015
Reflections on the Intersection of U.S. Tax Treaty Policy, U.S. Tax Reform, and BEPS
Tax Notes International
May 25, 2015
Will the Rush to Invert Spur Corporate Tax Reform? A Conversation
Tax Notes International
December 15, 2014
Surprise! Your Foreign Tax Credit Is Not Allowed Under Section 901(I)
Tax Notes International
January 14, 2014
Article from Tax Analysts, Switzerland and the U.S.: What We Have Here is a Failure to Communicate
Tax Analysts, by H. David Rosenbloom
June 4, 2012
FATCA & Foreign Bank Accounts: Has the U.S. Overreacted?
Tax Analysts
May 31, 2011
IRS Seeks Names of U.S. Account Holders at HSBC (India)
Taxmann-The Tax & Corporate laws of India-International Tax
April 18, 2011
Indictment of Offshore Account Holder Portends a New Round of Aggressive Enforcement
International Taxation
February 1, 2011
The Foreign Account Tax Compliance Act and Notice 2010-60
International Taxation
December 1, 2010
The Foreign Account Tax Compliance Act
May 11, 2010
The New U.S.-Italy Treaty: A U.S. Perspective
Diritto e Pratica Tributaria Internazionale
August 1, 2009
Resolución de Conflictos en Material Fiscal (in Spanish)
Revista - Instituto Colombiano de Derecho Tributario
May 10, 2009
Time for a Change: Toward a New Korea-U.S. Income Tax Treaty
Tax Notes International
April 20, 2009
From Arbitration to Zero Withholding: A Primer on the U.S.-Canada Treaty Protocol
Tax Notes International
August 20, 2008
Deductions for Non-U.S. Persons Under U.S. Income Tax Laws
International Tax Planning
March 1, 2008
Self-Created Transfer Pricing Adjustments
Tax Notes International
June 4, 2007
Tax Alert
Caplin & Drysdale
June 15, 2005
TNI Interview: H. David Rosenbloom
Tax Notes International
May 10, 2004
Banes of an Income Tax: Legal Fictions, Elections, Hypothetical Determinations, Related Party Debt*
The Sydney Law Review
March 30, 2004
Think About Subpart F: The Domestic Base Company
The Tax Magazine
March 15, 2004
Banes of an Income Tax: Legal Fictions, Elections, Hypothetical Determinations, And Related Party Debt
Tax Notes International
December 31, 2003
Why Not Des Moines? A Fresh Entry in the Subpart F Debate
Tax Notes International
December 15, 2003
Testimony of David Rosenbloom Before the U.S. Senate Committee on Finance
Committee on Finance, United States Senate
July 15, 2003
Deconstructing Section 905(c): An Examination of The Redetermination Rules After TRA 1997
Tax Notes International
April 1, 2002
Taxes Covered By §960(a)(3)
Tax Management International Journal
February 8, 2002
From the Bottom Up: Taxing the Income of Foreign Controlled Corporations
Brooklyn Journal of International Law
September 1, 2001
Arbitrage and Transfer Pricing Paper
Report of Proceedings of the First World Tax Conference: Taxes Without Borders
October 1, 2000
U.S. Proposed Global Trading Regs: Preliminary Questions Regarding Application
Tax Notes International
May 23, 1998
Commentary: Caplin & Drysdale Blasts Proposed Foreign Tax Credit Regs
Tax Notes International
May 5, 1997