The Office of the International Tax Counsel (ITC) develops and reviews policy, legislation, regulations, revenue rulings, revenue procedures, and other published guidance dealing with all aspects of international income tax law. ITC is responsible for advising the Assistant Secretary (Tax Policy) and other Treasury officials in connection with the formulation of the Administration's international taxation policy; for formulating, analyzing, and reviewing international taxation legislation; and for preparing the Administration’s testimony on such legislation. ITC advise congressional staff in drafting legislation and in documenting the legislative history of international tax legislation.
The Office of the International Tax Counsel is seeking to hire additional Attorney-Advisors. Priority application deadline is September 8, 2023. See job posting here for more details.
In addition to the above, the office is responsible for negotiating and reviewing income tax and estate and gift tax treaties with foreign countries and coordinating tax treaty matters with the State Department and the Congress. Two important purposes of these treaties are to help reduce international double taxation and thereby facilitate a freer movement of trade and capital flows, and to improve taxpayer compliance. In consultation with IRS, ITC is responsible for review of all Treasury regulations and IRS revenue rulings, revenue procedures, and other published guidance relating to international tax issues.
ITC attorneys serve as the official representatives of the United States in various international organizations including the Organization for Economic Cooperation and Development.
Organization
Michael Plowgian, Deputy Assistant Secretary (International Tax Affairs), provides advice and counsel to the Assistant Secretary related to international tax policy and tax treaties, and coordinates the international administrative guidance projects.
Lindsay Kitzinger, International Tax Counsel, provides executive direction for the attorneys who provide legal advice and analysis relating to international tax issues, including legislation, regulations, and treaties, and official representation of the Administration’s policy in international settings.
Jim Wang, Deputy International Tax Counsel (Acting), assists in providing executive direction for the attorneys who provide legal advice and analysis relating to international tax issues, including legislation, regulations, and official representation of the Administration’s policy in international settings.
Elena Virgadamo, Deputy International Tax Counsel (Treaty Affairs), assists in providing executive direction relating to U.S. tax treaty policy and provides legal advice and counsel relating to double taxation agreements, tax information exchange agreements, other bilateral and multilateral tax agreements, and official representation of the Administration’s policy in international settings.
Resources
The text of recently signed U.S. income tax treaties, tax information exchange agreements (TIEAs), the accompanying Treasury Department tax treaty technical explanations, and documents related to FATCA are available here.
Please note that treaty and TIEA documents are posted on this site upon signature and prior to ratification and entry into force. The text of most U.S. Income tax treaties in force is available from the Internal Revenue Service here.
Contacts
Office of the International Tax Counsel
Department of the Treasury
1500 Pennsylvania Avenue, NW, Room 3058
Washington, DC 20220