Rebecca I. Rosenberg is a member in Caplin & Drysdale’s Washington, D.C. office, having joined the firm at the end of 2000.
Services
Ms. Rosenberg’s practice focuses on international tax, including foreign tax credit questions, tax treaty matters and economic substance issues.
Highlights
From her prior work in all three branches of government, Ms. Rosenberg brings to Caplin & Drysdale’s clients a strong legislative, litigation, and regulatory background. As an attorney advisor and an assistant to the branch chief at the Office of the Associate Chief Counsel (International) at the IRS, Ms. Rosenberg worked extensively on economic substance issues. She was heavily involved in Notice 98-5 (relating to disallowance of certain foreign tax credits) and the IRS’s Tax Court litigation of Compaq Computer Corp. v. Commissioner, 113 T.C. 214 (1999), rev’d 277 F.3d 788 (5th Cir. 2001). She also contributed to confidential corporate tax shelter registration regulations published under section 6111(d).
She is the principal author of final regulations under section 904(d) and proposed regulations under sections 902 and 904. Ms. Rosenberg also participated in IRS litigation involving a range of foreign tax credit issues.
While at the IRS, Ms. Rosenberg also drafted Notice 2000-20, addressing issues raised by section 987 (and the proposed regulations thereunder) relating to recognition of currency gain and loss.
For the four years prior to her tenure at the IRS, Ms. Rosenberg served as an assistant counsel in the Office of the Legislative Counsel of the House of Representatives. In that capacity, she drafted tax legislation for the members and committees of the House and covered all areas of the Internal Revenue Code of 1986.
Professional Activities
Ms. Rosenberg has been a lecturer at numerous professional meetings at the American Bar Association, the International Bar Association, the D.C. Bar Association, the American Petroleum Institute, and the Tax Executives Institute.