Robert Stack has defied convention. National tax officials have
been disappointingly reticent throughout the BEPS project.
Taxpayers have been desperate to know their reaction to
international tax reform proposals so they can plan for the
changes, but tax agencies have been reluctant to talk. While
ministers have been in the spotlight at various G20 meetings
during 2014, their officials have hung back.
|Robert Stack is
a new entry this year
Stack, the deputy assistant secretary for international tax
affairs at the US Treasury has taken a different approach.
Throughout the year, but particularly since the first set of
BEPS reports was released in September, he has appeared at
conferences, including at International Tax Review's
Global Transfer Pricing Forum in Washington, made statements,
contributed to web seminars and spoken to the media to explain
where the US stands on the issues that have been addressed
already and those that will be discussed over the coming
The US will lose revenue if international tax rules are
tilted away from being residence-based to methods that consider
source first. That has not stopped Stack from appearing in
public in an effort to ensure everyone knows where the US
stands. The depiction by some that the US is against everything
the G20/OECD is trying to achieve in the BEPS project is not
One of Stack's targets during the year has been the
so-called cash box where taxpayers keep a large amount of money
in tax havens to escape their own country's tax rules.
"We [tax administrators] feel comfortable where we are
– defending the ALS [arm's-length standard] –
but I do think it's a service to the rest of the US community
to show you where the pressures in BEPS that you're reading
about comes in," he told the Washington conference.
"So now what do the tax administrations need to do and how
can the policy makers respond? The tax administrators can at
least say, number one, give us a little more transparency
because... if I see a company with 80% of their profits in
Bermuda but 80% of their sales in high tax countries, as a tax
administrator I think, 'I'm going to take a closer look at that
Stack has made sure everyone knows the US is fully engaged
in international tax policy development.