Skip to Main Content

Tax Notes Quotes David Rosenbloom on Tax Reform Open Questions

May 29, 2018, Tax Notes

The sheer number of changes made under the Tax Cuts and Jobs Act (P.L. 115-97) have resulted in a number of open questions.

. . .

“To the extent people ask me questions, I do the best I can with the statutory language,” David Rosenbloom of Caplin & Drysdale, Chtd. told Tax Analysts. “And I don’t think Treasury’s got any magic answers to these [questions] either. . . . Everybody’s got to do their best.”

. . .

Long Road Ahead

. . .

“Guidance from God wouldn’t solve these issues,” he said. Treasury might say that its position is, “We interpret black as white for [the] purpose of this section,” Rosenbloom said, and “nobody wants black to be black,” so Treasury will end up taking a position that’s contrary to the law.

Rosenbloom gave the 65 tax treaties and excess credits from previous years as examples of questions Treasury needs to answer. He added that whatever Treasury decides, somebody is “not going to be pleased.” Treasury has an “almost impossible job,” he added.

“This is a business where you live by the word [and] you die by the word,” Rosenbloom said. “If you get your words wrong, that’s a problem.”

For the full article, please visit Tax Notes' website (subscription required).

Excerpt taken from the article "The Business of Tax: ‘We’re Doing Our Best’ May Be New Mantra" by Zoe Sagalow for Tax Notes.


About Caplin & Drysdale
Celebrating our 55th Anniversary in 2019, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
New York, NY Office:
600 Lexington Avenue
21st Floor
New York, NY 10022


This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
©2021 Caplin & Drysdale, Chartered
All Rights Reserved.

Related Professionals

Related Practice Area(s)