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The Foreign Account Tax Compliance Act in 2010 Explored
LIVE Webcast
H. David Rosenbloom
Member
Caplin & Drydale
H. David Rosenbloom is a member in Caplin & Drysdale's Washington, DC office. He rejoined the firm in 1981 after serving as a Special Assistant and then International Tax Counsel and Director of the Office of International Tax Affairs in the US Treasury Department from 1977 to 1981.
Mr. Rosenbloom's major areas of practice include international tax planning and controversies, including transfer pricing and advance pricing agreements, the foreign tax credit and subpart F, tax treaty issues and competent authority proceedings, financial products and financial institutions, taxation of all forms of inbound investment, and individual tax compliance in a cross-border context.
Mr. Rosenbloom has served as a Tax Policy Advisor for the US Treasury, the OECD, US AID, the International Monetary Fund, and the World Bank in Eastern Europe and the Baltic countries, the former Soviet Union, Senegal, Malawi, and South Africa. He has consulted with and advised foreign governments and international organizations on international tax matters, and served as an expert witness in international tax disputes both in the United States and abroad. Mr. Rosenbloom has also served as an expert witness in courts in Canada and New Zealand.
Alan Winston Granwell
Partner
DLA Piper
Alan Winston Granwell is an international tax partner resident in DLA Piper's Washington, DC office. Mr. Granwell’s practice encompasses representing multinational corporations on cross-border planning, to include acquisitions, dispositions and business restructurings, IP migrations, services arrangements, repatriation planning, international transportation, cross-border leasing, transfer pricing and the use of bilateral tax treaties. He also advises high-net-worth individuals on cross-border tax planning and structuring.
Recently, Mr. Granwell has become active in advising investors from emerging countries engaged in cross-border transactions involving the United States and Europe and in advising financial institutions and their clients on international tax enforcement initiatives. He conducts an active administrative practice, regularly representing clients before the Internal Revenue Service and the US Treasury Department (including negotiating advance pricing agreements, conducting competent authority proceedings, advising taxpayers on voluntary disclosures, assisting clients in obtaining regulatory changes and tax rulings and advising clients on tax legislation matters).
Philip Garlett
Partner
Burt, Staples & Maner, LLP
Philip Garlett joined the firm as a partner in October 2006. He has an extensive background in international tax matters acquired through both private and public sector positions. My bio from the firm website is attached below.
Prior to joining the firm, Mr. Garlett was the Special Counsel to the Deputy Associate Chief Counsel (Strategic International Programs) and the Deputy Associate Chief Counsel (International Field Service and Litigation) within the Office of Associate Chief Counsel (International). In that capacity, he served as the office's international tax shelter coordinator and the National Office contact for international tax matters arising out of the west coast region. He advised both National Office attorneys, IRS field attorneys, and attorneys in the Department of Justice on a broad range of international issues including foreign tax credits, foreign currency issues, subpart F and passive foreign investment companies, dual resident companies, hybrid financial instruments, partnership allocation issues and many other matters. He also worked on a number of issues arising out of the Joint International Tax Shelter Information Centre (JITSIC) and was active in training Chief Counsel attorneys and IRS examiners in tax shelter strategies. In addition, he served as the front office reviewer on regulations and other guidance on non-resident withholding and information reporting guidance projects.
From 2001 to 2005, Mr. Garlett was the Head of the Harmful Tax Practices Unit at the Organisation for Economic Co-operation and Development (OECD) in Paris, France. The OECD is the premier international organization addressing international tax issues. The Harmful Tax Practices Unit serves as the secretariat for OECD's Forum on Harmful Tax Practices which is composed of high-level government officials from the OECD's 30 member countries who work to improve tax information exchange and eliminate unfair tax practices in member countries' preferential tax regimes. As part of his duties, Mr. Garlett personally conducted negotiations with high level officials from several offshore financial jurisdictions and OECD member countries and liaised with other international organizations, including the EU Commission. He spoke at conferences around the world including London, U.K.; Brussels, Belgium; Barcelona, Spain; Hong Kong, China; and Nanjing, China. He also represented the OECD in its contacts with the business community, including the OECD's Business and Industry Advisory Committee (BIAC).
Before joining the OECD, Mr. Garlett was a Senior Technical Reviewer in the IRS's Office of Associate Chief Counsel (International) where he had primary responsibility for the IRS's efforts to improve non-resident withholding and information reporting on cross-border payments. Mr. Garlett was the primary drafter of many portions of the withholding and information reporting regulations as well as the Qualified Intermediary Agreement. He also had primary responsibility for implementing the withholding and information reporting regulations and the Qualified Intermediary system and negotiated with banking associations in Europe and Asia as part of those implementation efforts. He has addressed withholding and information reporting conferences in the U.S. and abroad, including conferences in Paris, France; London, U.K.; Amsterdam, the Netherlands; Frankfurt, Germany; Tokyo, Japan; Hong Kong, China; and Singapore. He received the IRS Office of Chief Counsel's National Award for Technical Guidance for his work on withholding and information reporting.
Mr. Garlett also has had prior experience in the private sector. He was an associate specializing in international tax matters in the Washington, D.C. tax boutique firm of Lee, Toomey and Kent and later was a manager in the Washington National Office of Coopers & Lybrand. While at those firms his practice covered all the major areas of international taxation.
Patricia Ann Fisher
Director
PricewaterhouseCoopers
Ann Fisher is a Director on PwC's IRS Service Team where she assists clients in all aspects of domestic and international tax withholding, reporting, documentation, compliance, and remediation, including the impact of major legislative and regulatory changes. Prior to joining PwC, Ann had extensive experience at a large multinational bank where she advised various business areas globally to ensure the accuracy of U.S. tax benefits claimed under the Internal Revenue Code and treaties, including both current rules and anticipated legislative, regulatory, and other changes. Before joining the private sector, Ann served as an Attorney-Advisor for Tax Legislation in the Office of International Tax Counsel within the Office of Tax Policy of the U.S. Treasury Department. Prior to her Treasury experience, she served as an Attorney-Advisor and later as a senior Technical Reviewer in the Office of the Associate Chief Counsel (International) within the IRS Office of Chief Counsel.
The Foreign Account Tax Compliance Act in 2010 Explored
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