Global Tax 50 2014: Robert Stack

Robert Stack is a new entry this year

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. 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 year.

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 correct.

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 guy'."

Stack has made sure everyone knows the US is fully engaged in international tax policy development.