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Finance committee  Let me start with your second question, because I can do that fairly easily, I think. Let's say you have two related entities, A and B. A provides some kind of value to B, whether it's goods or services or loaned money, or whatever it provides, and B pays A for that value. What

February 7th, 2013Committee meeting

H. David Rosenbloom

Finance committee  They're very related—no doubt they're related—but if you put them all together and try to resolve them all with any one group or single approach, you're not going to end up solving any of them. It seems to me that a committee of the Parliament in Canada is going to be most able

February 7th, 2013Committee meeting

H. David Rosenbloom

Finance committee  Yes, I am quite familiar with transfer pricing. I've taught full semester courses on it for several years. I haven't done it recently, but I do a lot of transfer pricing work myself. Let me first of all describe what we're talking about. Transfer pricing refers to the price char

February 7th, 2013Committee meeting

H. David Rosenbloom

Finance committee  I applaud the involvement of political leaders in the whole tax area. I think tax is critical. You can't have a democracy without a functioning tax system, so I'm all for the G-8 and the G-20 being involved. However, at the current stage, we're in a very highly technical area he

February 7th, 2013Committee meeting

H. David Rosenbloom

Finance committee  Should I respond to that, or no?

February 7th, 2013Committee meeting

H. David Rosenbloom

Finance committee  Yes. I think it's important to distinguish the various subjects that have been talked about by all three of us. We're talking about a wide range of related but distinct issues. If the committee tries to do everything, it will end up doing, in my opinion, very little. It really

February 7th, 2013Committee meeting

H. David Rosenbloom

Finance committee  I'm quite familiar with TIEAs. I negotiated one on behalf of the Government of Liechtenstein with the United States. I'm a skeptic about TIEAs or exchange of information provisions having a very broad effect, because they tend to be one-off agreements. I don't disapprove of them

February 7th, 2013Committee meeting

H. David Rosenbloom

Finance committee  Yes, of course. I think there's a long tradition of secrecy of tax information, and there are reasons for it. Tax administration in my country and in many countries depends on achieving a certain level of willingness of the taxpayer to comply with the laws, and it is thought tha

February 7th, 2013Committee meeting

H. David Rosenbloom

Finance committee  I thank the committee for the invitation to make this presentation. My name is H. David Rosenbloom. I am private a tax attorney and a professor of tax law at New York University's School of Law. I have specialized for nearly 40 years in international or cross-border taxation.

February 7th, 2013Committee meeting

H. David Rosenbloom