Blogs | Contact Us | Join Our Mailing List | Home VIEWPOINT Toulouse: No Treaty-Based Credit? October 25, 2021, Tax Notes International To view a PDF of this Article, please click here » H. David Rosenbloom is a member with Caplin & Drysdale in Washington, the James S. Eustice Visiting Professor of Taxation and the director of the international tax program at New York University School of Law, and a member of Tax Analysts’ board of directors. Fadi Shaheen is a professor of law and a Professor Charles Davenport Scholar at Rutgers Law School in Newark, New Jersey. In this article, Rosenbloom and Shaheen maintain that the U.S. Tax Court’s decision in Toulouse — that U.S. tax treaties with France and Italy do not provide a treaty-based foreign tax credit against the net investment income tax — is mistaken. Copyright 2021 H. David Rosenbloom and Fadi Shaheen. All rights reserved. For the full article, please visit Tax Notes' website (subscription required) or click the PDF link above. RELATED PROFESSIONALS H. David Rosenbloom RELATED PRACTICE AREA(S) International Tax © 2021 Caplin & Drysdale, Chartered | Attorney Advertising | View Mobile Version | Terms & Conditions | Privacy Policy | Sitemap | Print

Blogs | Contact Us | Join Our Mailing List | Home Scott Michel Addresses Ethical Issues in International Tax at IFA Winter International Tax Conference December 9, 2021, 11:00 AM to 12:20 PM Panelist: Scott D. Michel Program: Ethical Issues in International Tax Practice Event Sponsor: IFA USA 2nd Annual Winter International Tax Conference Registration: Click Here To Register International tax practitioners frequently grapple with ethical questions arising from representing clients in both tax planning and tax controversy matters. These issues include conflicts of interest, due diligence, questions over privilege and confidentiality, tax return reporting and disclosure matters, and advice to taxpayers who have engaged in non-compliance. Such questions raise issues both under the applicable disciplinary rules and IRS Circular 230. The panelists will discuss the landscape of ethical rules and work through a series of hypotheticals that frame the relevant issues and provide practical and instructive guidance. RELATED PROFESSIONALS Scott D. Michel RELATED PRACTICE AREA(S) International Tax Tax Controversies Tax Crimes White Collar Defense © 2021 Caplin & Drysdale, Chartered | Attorney Advertising | View Mobile Version | Terms & Conditions | Privacy Policy | Sitemap | Print