Five minutes with... Randi Rosenberg, Siemens
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Five minutes with... Randi Rosenberg, Siemens

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Rosenberg, Siemens' New York-based chief tax counsel, tells ITR about Ben Affleck comparisons, welcoming challenges from US tax authorities and what makes tax cool

Someone asks you at a party what you do for a living. What do you say?

The truth: I’m a tax lawyer. I know, it sounds boring. But it’s like figuring out a puzzle. And who doesn’t like puzzles (says this tax lawyer who obsessively undertakes the New York Times Spelling Bee every day)? 

Instead of the geek with her nose in the books and a pencil behind her ear, I like to envision Ben Affleck in The Accountant with a hint of Tom Cruise from The Firm…as a female and without the crimes of course!

Talk us through a typical working day.

Siemens has generously allowed me to work from home since I had my second child in 2000. I typically exercise on an elliptical first thing in the morning and then hit my desk by 9am. As Siemens is headquartered in Germany, I usually have a few emails to address at the outset. Often calls as well.

Once the more urgent issues of the day are addressed, I generally try to turn my attention to responding to more complex, time-consuming matters, such as tax issues that have arisen in the context of a tax audit or digesting new or proposed tax legislation for potential impacts on Siemens.

I’m more visual than aural, so I enjoy summarising my observations, positions and conclusions in writing. And I always make time for my team to discuss all of their issues with me.

What are you working on at the moment?

Back to the movie examples – that’s top secret confidential! Just kidding. Siemens always has numerous US state tax audits pending, and we are a large corporate taxpayer which has been audited by the IRS for years. So that takes up a fair amount of time (just responding to document requests!), even though I have a truly excellent audit team. 

In addition, I work hard to keep abreast of recently enacted and pending US tax legislation and regulations that could impact Siemens and to ensure that tax issues important to the company are appropriately communicated. As a company that spends over $1 billion a year in the US on R&D, we are watching closely to see whether Congress enacts any tax legislation this year.

On a daily basis, I respond to a wide variety of tax questions that arise from business and tax colleagues, not just on traditional corporate tax planning matters, but also tax issues involving compensation and benefits, state nexus, cross-border activities, philanthropic matters, M&A, and more.

Finally, these days, my team is always engaged in seeking opportunities to utilise the latest technologies to automate complex tax processes. Simply trying to understand what they are doing could be a full-time job for me!

What is the most exciting aspect of your role and what is the most stressful?

I love brainstorming solutions to thorny tax problems – whether for Siemens specifically or for society more broadly. 

For example, the proposed Base Erosion and Anti-Abuse Tax (BEAT) regulations issued by the US Department of the Treasury in late 2018 contained an error regarding the applicable BEAT rate. I very much enjoyed conceiving of ways to explain that error to the responsible Treasury personnel and it was so personally gratifying when they corrected it in the final BEAT regulations.

I feel similarly about the funding rule in the recent US Stock Buyback Excise Tax Notice that was issued in early 2023 and the related Proposed Regulations that were recently issued. But, again, I am hopeful that Treasury will correct some of the more problematic issues we identified when they finalise the regulations.

I also enjoy collaborating with colleagues to defend Siemens from what are sometimes specious claims by various US tax authorities. It helps that Siemens is a good corporate citizen and a robust and compliant US taxpayer. We always have solid legal grounds for any tax positions we take. And when we make mistakes, we own it. But that doesn’t mean our positions are not challenged, it just means that we welcome that challenge!

I am a high-strung, neurotic worrier – about almost everything in life. But I try to keep it in check and not get too stressed about situations that are beyond my control. Despite how hard I work, I make mistakes like everyone else. That is when I feel the most stress: when I worry about the consequences of my own (or my team’s) mistakes. But then I try to remind myself that Siemens is paying me to do my best. If I were perfect, I would be making a lot more money!

Tell us the key characteristics that make a successful tax professional.

For the most part, I think it’s the same characteristics that make a person successful in any field: drive, diligence, focus, intellectual ability and curiosity, genuine interest and engagement in the work, a good and kind personality.

I think self-awareness is something that people should value more. I am always trying to think about my weaknesses and how I can improve. And I find that I most enjoy working with others who do the same.

What is the most common misconception about your work?

That we are always looking for nefarious tax opportunities. In fact, I spend most of my time trying to ensure that Siemens appropriately complies with all US federal and state tax laws! 

What or who inspires you?

Unfortunately, I’m like a puppy – I crave positive feedback. Almost nothing makes me happier than someone telling me I did a good job. Sad, but true. 

If you weren't a tax professional, what would you be doing?

I was a disengaged finance major in college. Then I took a computer programming course and loved it and wanted to switch majors. But it would have required me to spend an extra year, which, at the time, I didn’t feel I could justify. But my daughter is now a software engineer and so perhaps I channelled it that way! 

Any advice you would give your younger self?

I honestly can’t think of anything. My path has not been perfect. I have faced many personal and professional hurdles. But I metaphorically embrace the refrain from the Rascal Flatts song: God Blessed the Broken Road that led me [here]. 

Tell us what makes tax cool!

Back to the puzzle analogy. I feel like all of the tax rules have a purpose or rationale and if you figure that out, it’s easier to understand the way the rules work. And figuring out how the rules work together and get to a rational answer (in light of their designed purpose) is like completing a puzzle.

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