Festschrift for Prof. H. David Rosenbloom


Rosenbloom & Festschrift cover

This website celebrates the career of H. David Rosenbloom, Faculty Director of NYU’s International Tax Program. It also announces the publication of a Festschrift in his honor to mark the occasion of his 80th birthday. Many authors from around the world contributed chapters to the book, Thinker, Teacher, Traveler: Reimagining International Tax. You can read the Preface and Table of Contents.

Many other friends and colleagues contributed stories as part of our celebration. You may read those stories below, or add to them here.

Diane Ring, Interim Dean at Boston College Law School

One of the greatest fortunes of my legal career was commencing it under David’s guidance. His enthusiasm for challenging and novel tax questions was contagious; his depth of knowledge, critical thinking, and trenchant analysis were daunting and inspiring. And along the way he instilled two strong principles of practice: Always read the code for a new problem no matter how many times you have read it before; and speak up if someone’s explanation doesn’t seem to make sense. . .  because it probably really does not!

But beyond his tremendous legal talents, David was immensely kind, supportive, and generous with his time. I could not have wished for a better mentor.

Tulio Anderson Soares de Lira, Tax Lawyer at DeLira Consulting and A-Law International

I remember complimenting the various decoration artifacts and statuettes in Rosenbloom’s apartment, during a lovely dinner party. Little did I know that each one of them had an incredible backstory of his and his wife’s travels around the globe, and there was a special spot reserved for his upcoming trip to Greece (as I recall). But not the touristic Greece we know, a quasi-deserted island, as I was told, full of trees and cliffs… to be visited on a donkey back! Rosembloom’s energy and disposition are indeed unmatched! I wish you all the best, professor, and many more trips to come!

Lucas de Lima Carvalho, Global Head of Tax at EBANX

I remember the first time I went to a lunch lecture hosted by Prof. Rosenbloom at NYU. All the usual suspects of the International Tax scene were there, including Lee Sheppard, whom I met (and would later join at Tax Notes). In that first meeting, when I asked Prof. Rosenbloom the idea behind discussing complex topics in that ""setting"", he said something to the effect of ""just grab a sandwich and a soda, Lucas. You'll find it fun."" And for the next 8 or 9 lunch lectures, that's what I experienced: a relaxed environment in which Prof. Rosenbloom made us feel more and more ""integrated"" into the key debates of International Tax. Prof. Rosenbloom, it has been an honor and a privilege to have been your student and to have known you for all these years. Your influence as a mentor is something I carry with me, in professional life, to this day. Thank you.

Marlin Risinger, International Tax Counsel, General Electric (retired)

I’ve known David for almost 40 years, in many different roles. He was my mentor at Caplin; he persuaded the US Treasury to hire me at the Office of Tax Policy; he was my partner when I returned to Caplin; and he was my advisor for many years when I went to GE. He was a professional inspiration to me always. But most valuable to me has been his friendship through all of these years. Surprisingly, my fondest memory of David has nothing to do with the tax law. After I moved to Connecticut with GE, I sent him a note and told him that I had started reading Proust’s In Search of Lost Time. He immediately replied that he had always intended to read it too and would join me in the adventure, with the difference that he would be reading it in French. We read along together for more than a year, regularly exchanging emails on passages that we found most interesting, beautiful and compelling. When we finally finished volume 7, David sent me a note and said he was going to do the only thing that made sense after such a wonderful experience: he was going to start again at page 1 and read it through a second time. Which he did! Soon after, I moved to London with GE. On one of his many visits, in 2000, David and I went to see Harold Pinter’s play based on Proust's novel at the National Theater, located along the Thames. I remember walking across Waterloo Bridge after the performance, reminiscing about the miracle of the novel and how much we had enjoyed sharing it. Thank you David for being the very best tax lawyer and adviser, and even more importantly, for being such a wonderfully interesting, stimulating and engaging person in every way.

Joni Walser, Adjunct Professor, UNC School of Law

A couple of favorite Davidisms: “What do you mean ‘more likely than not?’  I think it’s more likely than not the Tax Code will be repealed in my lifetime.”  “Read the Code.” No one takes more delight and finds more humor in the tax law than David.  It has been my honor and pleasure to spend so much of my career in his giant shadow, to learn from him, to witness his brilliance, to see that twinkle in his eye as he spots the humanity, irony, and fun in the cases before him.  I raise a glass of single malt to him on this birthday. Ever youthful in outlook, boundless in energy and intellectual curiosity, I urge David to begin thinking where and how to celebrate his 90th. Noi Non Potremo Avere Perfetta Vita Senza Amici. Cent’Anni, Joni Walser

Gabriel De Sá Balbi Cerviño, Tax Lawyer

Dear Prof. Rosenbloom, although the time we were allowed to meet was brief in essence, and shortened by the pandemic, I am very happy to have had the opportunity of being your student, in the Tax Treaties Class, and also to be in the Program that you directed, and took great care of, every day. We had fun during my time at NYU, and even began some projects together afterwards. Now life is more busy than ever, as I am studying for the Bar Exam. Still I am certain I will pass it, due to all the knowledge and skill I learned while at NYU. Thank you for everything, and happy birthday.

Nathalia Brandao, Head of Tax at Hotmart             

Dear Prof. Rosenbloom, Happy birthday! My best wishes for such an inspiring Professor. I recall my first meeting with you, in the first days of my ITP LLM Back in 2013 (class of 2014), when you recalled that I was from Salvador, Bahia, because of  my personal statement. It was a simple gesture but proved me that all the energy and effort I applied in preparing to be admitted to NYU really worth it. Happy birthday!!

Joe Guttentag  

Must have been 1978 when I received a call from Stanley Surrey.  He had read that David Rosenbloom had been appointed International Tax Counsel.  He indicated he didn’t know Rosenbloom and wondered whether Rosenbloom was right for the job,. Did he really know international taxation, and what were his policies?  If I remember correctly, I didn’t know Rosenbloom or at least didn’t know him well.  Stanley “directed”  me to go to see Rosenbloom, and check him out, and if necessary educate him.  Of course I did as directed.  When I met with David I just said that since I had had the job I would be glad to be of any help that I could.  I was then treated to an hour lecture on international taxation and what needed to be done.  I remember none of the details but was able to assure Stanley that Treasury had the right guy.  That is our Stanley—and our Rosenbloom!!

Ramón de la Torre Medina

Congratulations Dear professor! It’s great to have you every Friday at lunch discussing taxes!  I hope all is well, enjoy!

Luis R. Salinas, Tax Counsel

I have a lot of good memories from professor Rosenbloom. The one I remember the most, as it had a great impact on my career, is that I visited David three years after graduating from my LLM for some career advice. I had a good job but didn't feel fulfilled as I did not have a lot of work. After telling professor Rosenbloom my concern, he said "It's normal in your career for your workload to decrease at times, but not for too long, if it's for too long you should look around" then he suggested me to look into what the Mexican Taxpayers' Advocate Office (Prodecon) was doing. The next year I got a position in Prodecon as Director General of International Affairs, participated in UN tax meetings around the world and ended up being the acting head of the Agency. I am very grateful and lucky for the dedication that professor Rosenbloom gives to his students and alumni. Thank you for everything David.

Chidi Ukandu, Tax Lawyer

One word: “Genius”.

Guillermo Teijeiro

This is a first of a series of anecdotes which are aimed at portraying David’s human and professional values as seen by someone who has the privilege to be his student, worked with him as a young foreign associate at Caplin & Drysdale, and who counts him as a lifelong friend.

1) Take the others’ perspective and consider their personal interest as yours regardless of who you are

Back in 1985, after graduating from HLS, where I took Dave’s first International Tax Course , I was working at Caplin & Drysdale, with the International Tax Group led by Dave. We were inthe final moments of a 6-month project for the National Tax Foundation on the tax treatment of high-tech companies in the US, Germany, and Japan.  The deadline for the Final Report was Monday. The previous Friday a close friend from Argentina, who was studying at HLS in 1985, announced that he would be visiting us over the weekend.

Additional data: it was my third year in the US at a time where communication means with friends and family were letters (US post mail), voice messages recorded in a cassette (CD-room predecessor) and sent to the family through an occasional visitor, and phone (analog system) for emergencies. No Internet services (including video conferring) nor mobile communication were available.

First scene (Friday late afternoon):

Guillermo: “Dave, a friend of mine in coming to town from Boston tonight to visit me. I haven’t seen him since April 1983. He will stay home and I wonder whether I could take Saturday off to enjoy his presence.”

Dave: “No way. We have to submit the Report on Monday and cannot take the risk of not finishing it by then.”

Second scene (Saturday Morning at C&D)

I was there working as usual (remember, no home working possible in the mid-80’), after having tried to digest Dave’s answer overnight, and still ruminating my anger because of my frustrated long-awaited weekend, when Dave appeared wearing jeans and a t-shirt and said: “Go home. I will take care of everything pending over the weekend.”

He had fully understood what that weekend meant to me, my wife Liliana and my kids, and out of his generosity and humility, took my place in the front line!

2) Professionalism, push yourself to your very best!

Mid-1985 once more. A lawyer from Alaska requested an assessment on the possible outcome of a tax case pending before the US Tax Court. Dave asked me to evaluate the case and arguments and to assess the chances of success, without charging excessive professional time.

Believing I had done a good job, I came to Dave’s office a couple of hours after and in a firm-tone of expression voiced: “Dave, this is OK; the client’s position is very well articulated based on scholars’ opinions and available case law precedents.”

In my entire professional life, I have never regretted more saying such nonsense . But what I learned then, the hard way, became one of my main mottos ever after.

Dave’s looked at me firmly and emphatically spoke out; he said "Guillermo, do you by chance believe that someone requested our opinion and paid the fees of a tax law firm in Washington DC just for us to tell him that his opinion is OK? Go back, do your job and come back later with the best work you are capable of.”  Needless to say, after such a diatribe my ideas on the case's nuances gushed forth without continence.

3) Build a successful career on a solid, balanced, personal life

Back in the '70s, the business lawyer’s role model that spread worldwide was that of the New York lawyer working for a large law firm, someone practicing in a very competitive and pressing environment, who was capable of even mortgaging his personal life to become a successful professional.

When I came to the US to study and work, I had already practiced law for some years following that model, imposed by the example of partners of my Argentine firm who had internalized that idea after taking a more or less prolonged training periods with large corporate and financial firms in NYC . 

More inclined to keep a balanced way of life, I had been always in conflict with the idea of subordinating every aspect of my personal life to a successful career in law. Something made a strong noise in my inner self in those years so that when I came to work with Dave in D.C., I put much attention to his way of life and, in fact, I was pleasantly surprised by the time he devoted to his family.

Dave drove a blue scooter by then and used it to take his daughters from school to home every day at noon or so. He did it even if the CEO of one of the then fancy names in the Firm's clientele (e.g., Columbia Pictures) was calling him while he sneaked out to fill his father's role.

I was so astonished by Dave´s freedom from the NYC lawyer’s model, which role so worried me and made me felt guilty every time I was not charging time in my timesheets, that I once told him about it. His answer calmed me down and helped me to seek a balance between my professional life and my personal life ever after.

He simply explained to me that the NYC business lawyer’s way of life of the '70s had proved to be a mistake that had ruined many lawyers’ personal and family lives, and added “Guillermo, when a client realizes that before being a lawyer you are a person with the same personal and family interest he has, he comes to value you more than if he feels you are a sort of a legal robot.” (Yes, the word robot existed at that time!)

I am 66 now, and how many times I have had the opportunity to verify in practice the truthfulness of Dave’s words! Good, longstanding clients do not trust in legal robots, but on highly efficient lawyers who are first, and above all, good persons with a solid personal life on which they have built a successful career in law."

So far, I have tried to portray some of Dave’s many personal values through anecdotes which have taken us back to the mid '80s so that, I wish to emphasize something that may have been overlooked. I have been taking about a man in his 40s, not in his 80s, someone who still being young and in the middle of his ascending career as tax lawyer and tax professor, was inescapably guided by strong personal values. Someone who showed to all us that you can search for and reach the sky without turning your back on your inner self, without alienating it.

4) Why me?

A couple of year ago, by Christmas time, I decided to pay tribute to less than twenty friends who, one way or another, have had a positive impact on my life. Of course Dave was one of them. The tribute took the form of a Christmas salute which reads as follows:

“…You may ask yourself why are you receiving this message, and the answer (and possibly the circumstances) should be known to you and me, although the inexorable passage of time may have put them in the oblivion chest.

For some reason, whether close or far in time, more or less clear or more or less diffuse to you, but specifically concrete and present for me, you are part of a list of people a little older than me (but not much) who has been and continue to be very important because you have left me something along my life: A teaching, an example, a boost, an opportunity, something that directly or indirectly enriched me as a person or as a professional, helped me to forge the path that brought me here, build and rise in some aspect of my life…

…Our relationship may have been lasting or more or less circumstantial, in context as different as the university cloisters, court halls, office, academia, professional travelling or personal friendship. It might have lasted until today or have been interrupted earlier for a variety of reasons, even beyond our will, but that attitude of yours that I wish to cheer today remained magnetized, indelibly fixed to the particular circumstances that we once shared. It left a mark in my soul that I wish to remember today and let you know about it.

I wish you a Merry Christmas and a wonderful 2020”

As you can realize from the last line it was a pre pandemic message…

Dave’s reaction to my message draws a clear picture of his modesty; he simply said, like someone who receives something undeservedly, “This is quite moving.   Thank you for sending it.” I could have said he was at the very top of my list but I did not. Dave, you are! Happy 80th anniversary!!!

Hidehiro Utsumi, Partner

Congratulations on your eightieth birthday! All of us wish you a day filled with happiness and a joyous year ahead. Happy birthday!

Niv Tadmore, Partner

David and I had a few dinners together over the years but the best one was this:  I was in DC for a day so planned with David to catch up after my client meeting and then take a late evening flight to Pittsburgh.    My client meeting went overtime, but we still wanted to catch up.  So David kindly offered to take me to the airport, and we had a great (albeit unglamorous) dinner there where David unpacked the TCJA within 30 minutes! "

Antonio H. Figueroa, Director of International Tax Affaires at Dirección Nacional de Impuestos, or National Tax Directorate, within the Argentine Treasury

Hi boy, years are an administrative issue, they surge from birth registers and ID documents, what matters is our young spirit and the will to move forward with our projects. In that sense, we are very young. Happy birthday my young and ancient friend that, according to those cases of mutual feelings, even without seeing each other and beyond distance (it seems the paragraph of a song), one always carries with oneself one's dear friends, those which have a special place in our heart.

I keep multiple memories of our encounters, our difficult negotiations, the advice about closing the agreement by the dear professor and, in the end, friend, Stanley Surrey, of very pleasant moments that we spent together there and in Buenos Aires. I´ve had counterparts of the highest technical, cordiality and friendliness levels, because I’ve had a great time with Steven Hannes, Marcia Field and you.

I’ll never forget your gesture of going to New York, with your beloved Lexus, so as to, following my exposition in the postgraduate course that you ran in NYU, and after eating exquisite sushi--that you always recommended at a restaurant near the university--travel together toward Harvard going over marvelous places. Unforgettable. The next day (23rd of October of 2002) we celebrated my birthday (5.) dining at a restaurant of your choice in the surroundings of Harvard University.

Finally, another one for the memory is the welcome in the first negotiation in Buenos Aires that, unbelievably, the Secretary of Public Revenue gave you in French, and that I don´t know how is it that we did with Pettinari and Kosanich, who were with me in the negotiations, so as not to bust up laughing.

Now it’s time: We wish you an excellent day, a very happy birthday (in Spanish we use the expression “for many birthdays more”) and hope we meet soon.

Marta, María Gabriela, María Alejandra and I*.

Hug, my dear friend and my warmest regards to your lovely family

*Tony Figueroa (member of David's international taxation band)

Raul Villarreal Garza, Tax Attorney

David’s command of the Italian language is a hidden gem.  My father, a Spanish native speaker, did not speak English, but learned Italian late in his life.  At the graduation celebrations in 2010, my father and David had a long conversation in Italian about family, education and life.  My father always cherished that conversation and the opportunity to speak with the head of my program.  Thank you for this David!

Gareth John Redenbach, Barrister (Australia)

I was taught by Prof. Rosenbloom in my LLM at the University of Melbourne in 2011.  A year later, I left my law firm in Australia on short notice and, jobless, accompanied my partner to her new role in New York.  From the day I landed in New York, David never hesitated to include me in the broader NYU network and include me in the international tax community.  He was also never too busy to discuss topics of interest (particularly at Sushi Yasaka on the UWS). 

Later, working as international tax counsel for Macquarie Group in New York, the infrastructure group hired an exceptional international tax counsel in Mexico (Juan Valles Torrescano). It turned out he was an NYU graduate and greatly influenced by David as well – so trips to Yasaka from time to time became the three of us.  David's influence on international tax is so profound and complete that Juan and I never stopped to consider it unusual that an Australian lawyer and a Mexican lawyer thrown together by chance would share such a profound intellectual influence and friendship with the same person.  The sheerly positive scope and breadth of David’s impact was illuminated to me when I started attending the annual IFA Congress: while everyone knows David, I am yet to meet a person who says a bad word about him intellectually or personally.

Despite an intellectual rigor and importance few people ever achieve in a field, David has never stopped dealing and engaging with people without pretence or self-importance and as equals.  Like many people he has taught, I feel profoundly lucky to have been taught by him and his continued passion and interest in both international tax and the people who practice it.  Thank you.

Guillermo Edelman, Manager   

I am always amazed at Prof. Rosenbloom's excellent memory. No matter how much time has passed since last seeing each other, he always remembers his pupil's names, country of origin and more or less what he/she is up to nowadays.

Wishing Professor Rosenbloom good health, happiness and sharing his wisdom and camaraderie for many more years.

Young Ran (Christine) Kim, Associate Professor of Law

When I was swamped in his next door office at Caplin & Drysdale, David brought me to his office and showed me how beautiful a sunset glow could be in Washington, D.C.

He walks about three to five miles almost every day, which motivates me to workout despite whatever schedule I have.

David really liked my suggested itinerary for the old town of Seoul during his business trip in 2012, which was actually overwhelming even for young backpackers. And when he returned, he gave me tons of red ginseng products that he brought from Korea. When I met David and Carla again in Seoul at the IFA 2018 Congress, they were buying two more luggage for souvenirs.

I was so surprised when David attended my JSD oral defense at NYU School of Law in the middle of his busy schedule. When I asked him how he made time to make it, he told me, ""I know that this is an important event of your life. I thought I should come and wanted to be a part of it.""

Whenever I seek his help, he asks me, "Is that what you want?" If I say "Yes," he does his best to make that happen. And that always has happened.

David is that kind of person. He is extremely talented, a cosmopolitan, down to earth, and sympathetic to everyone that needs his help. He is like a father figure to me in America.

Pasquale Pistone, Professor

Dear David, we have met many times in so many countries of the world! I was among the lucky ones who could not only learn from you, but also share quality time together with you.

My favourite memory with you is when you visited my home town in Naples, Italy.

I took you to a park on the outermost tip of the city overlooking the whole bay.

That inspiring place brought us to talk about Italian literature, a discussion that I greatly enjoyed and still clearly remember!

You are really special!

Your friend


Ana Claudia Utumi, Partner at Utumi Advogados        

One of the opportunities I had to speak at the ITP Friday Luncheon was in 2017. When I was thinking about what subject to speak about, I thought the students would be interested in learning about the advances of BEPS in Brazil. When I talked to David about my idea, he replied - "Can you speak about Car Wash [anti-corruption] Operation"? At that time, the Car Wash Operation was all over Brazilian and international newspapers, with an impressive number of people involved and amounts recovered! I have to confess that it was challenging to prepare a presentation on such a topic involving tax and compliance matters, not on the usual international tax matters.

Nevertheless, the luncheon was interesting and lively, with questions and comments from David and from the students! And of course - the biggest prize was to receive his compliments due to this presentation! David, thanks so much for your attention and generosity towards me! Not only on this occasion but also every time we have the opportunity of being in contact! And thank you for admitting me to the Practice Council back in 2013, after a great chat during IFA Copenhagen dinner!

 Shun Tosaka, Manager, EY International Tax and Transaction Services

Congratulations, Professor Rosenbloom. You have been a great mentor to me throughout my career as I went back to my home country and then came back to the U.S. I am impressed to see how Professor has been checking each alumnus and alumna's status and recent work and has been in touch with them. I also appreciate Professor hosting ongoing opportunities open for alumni, such as ITP guest lecture series with exciting topics. 

I recall the night in my LL.M. year when ITP students were invited to his home and had fun. Time flies, but the moment has seized us since. I hope Professor Rosenbloom's ongoing journey will get more exciting and fun! 

Porus F Kaka, Senior Advocate (India), President IFA (NL) 2013-17

David's enthusiasm is unlimited and invigorating. His knowledge and interests go far beyond the Tax World.  I share a few, out of many, of the pleasant interludes and experiences I have shared with David in the many years that I have known him:

1.        Shopping for Celedon pottery on the back streets of Seoul, South Korea and being warned to look out for fakes!

2.        While enjoying a Parsi meal at my residence -David gave perhaps the best compliment my residence has ever received when he stepped out on the Terrace and saw the Majestic Taj Hotel bathed in light and remarked that he felt he was in Milan (Italy) looking out on the Duomo!

3.        Fine Dinners in New York on many an occasions

4.        Watching Carla and him setting the dance floor ablaze after receiving IFA’s Honorary Membership in Madrid at the Gala Dinner at IFA’s 70th Congress!

5.        Working on fascinating treaty cases through the Indian Courts

6.        A wonderful Host at NYU- for my David Tillinghast Lecture in 2016

 On every occasion David's knowledge, interest and keenness not only to participate but explore has been a tremendous source of inspiration for me. 

Above all, he's also been exceptionally kind to those who are far and away junior to him both in the profession and in age.   It has been a special privilege to know such a Titan in the world of Tax Law personally

Porus Kaka

Mumbai June 2021

Chloe Burnett, Senior Counsel

Where to start?  I love how David always responds with gusto and relevance to every remark in conversation.  Has has the ability to speak with anyone, no matter how junior they are or how different they are, and treat them as an interesting individual.  I love how when you are at a function with a dance floor, David and Carla will be carving it up and often the last to retire.  And David's energy for urban walks.  He has visited most cities in the world, I bet he has covered them all on foot too.  When he described a walk he did in Sydney in one day (the from the city to Manly) I was very impressed, it is something most locals could not achieve in a day.  In a court case where David was (unfortunately) an expert witness for the other side, I had the unenviable task of trying to persuade the Judge that David's evidence should not be admitted.  I was unsuccessful.  I have many tax-related thoughts too, and I have covered some in my chapter.  One more to add is that David's 2003 speech in Sydney about legal fictions, elections and related party debt had a lasting impression on me at the time, as someone just starting my international tax career.  It was also ahead of its time, as so many of David's tax pronouncements have been.  A thousand thanks to the organisers and congratulations and best wishes, David!

Yoshihiro Masui, Professor, UTokyo

Carla, David, and Mount Kilimanjaro --- these are the three words that mark my visit to NYU in early 2008. The Kibo summit still waits for you! Yoshi

Stef van Weeghel, Professor

"Just a little testimony to your endless energy, David. You may remember, a few years ago, when I was in DC for an arbitration, I emailed you to see if we could get together for dinner. The only possible evening was the day of your return from a stay in Germany. Your reply: ""Stef, you will have had your fill of restaurants, so I will cook you dinner at home."" Long trip, time difference, jet lag, and yet you were prepared to cook dinner for us. In the end, I had to leave a few days early and we did not meet...


Yuko Miyazaki, Lawyer; Former Justice of the Supreme Court of Japan

In my memory, Professor Rosenbloom’s International Taxation class in the winter semester of Harvard Law School in January 1984 was spectacular.  I believe that it was his first teaching class at Harvard.  The class was full of liveliness.  The winter semester at that time was a three-week intensive term, each student selecting only one subject and attended the class 2-3 hours every morning from Monday through Friday.  Partly because of such intensiveness, and of course mostly because it was the David Rosenbloom class, I felt that all students attending that class were sharing the focused moments and intellectually uplifting feeling.  Since then, I have had valuable opportunities to work with him for some mutual clients.  He was, and has always been, an excellent professor and excellent lawyer and special mentor to me showing how interesting and exciting to challenge international taxation issues, which are sometimes conflicting each other, and analyze them creatively, for which I am truly grateful.  When I was appointed to a Justice of the Supreme Court of Japan, I was extremely honored to welcome David, my special mentor, in my chambers a couple of years ago.  Having spoken to him in my chambers, I found that his interests in exotic and trans-national subjects are unchanged, and still as high as when I first met him.  Wish him the best!

Kei Sasaki

Happy 80th birthday to you!! In Japan, the age of 80 is called "Umbrella Happiness (sanju)" because "80" in kanji (Chinese character) is similar to the Chinese character for umbrella, and it is greatly celebrated. Due to COVID-19, I could not give an umbrella to you, but I'm very much looking forward to giving one to you when we meet again in NYC or Tokyo. Please take care of your health and a happy life in your 80s.

Scott Wilkie, Distinguished Professor of Practice, Osgoode Hall Law School, and Senior Counsel (Retired Partner) of Blake, Cassels & Graydon LLP

First, David, I do want to send you my best wishes and to say what a privilege it is to have been asked to share in this celebration. Second, I want to thank you for your generosity, intellectual and other encouragement, and willingness to say what others no doubt are or ought to be thinking but are less courageous, confident, and insightful about speaking and writing.

Finally a more serious message that in fact ties the above thoughts together.  Among all your writing three essays stand out as arresting to me in my professional and academic lives (which yours demonstrate are inextricably linked!) as inspiration to think broadly about even the seemingly most obvious:  "Why Not Des Moines?", "Banes of an Income Tax - Legal Fictions, Elections, Hypothetical Determinations, Related Party Debt", and "Where’s the Pony? Reflections on the Making of International Tax Policy".  Why not indeed? Tax law as a manifestation of and fueled by embedded private law determined choice - yes!  Buried in the pile of often confusing interlaced tax and legal notions is something meaningful - if we search; if there's evidence there's a pony, it may well be there!  Animating features of your curiosity and forceful expression - and enduring and frequent inspiration to me. Thank you for that inspiration and your long friendship. Warmest best wishes, Scott

Shigeki Minami, Attorney at Law, Japan, ITP Practice Council member

I would like to wish Professor Rosenbloom a very happy 80th birthday!  When you visited Japan, we accompanied you to meet Justice Yuko Miyazaki, your former student, at the Supreme Court of Japan.  It was a great experience to see esteemed jurists of the U.S. and Japan together on the bench of the Supreme Court of Japan.  We are all deeply indebted to you for your contributions to our tax education.  I look forward to seeing you in person at the NYU lunch seminar next year.  

Kenji Horiuchi,  partner, Nagashima Ohno & Tsunematsu

Professor Rosenbloom: Greater than Professor. What an honor it is to wish you a most wonderful and joyous 80th Birthday. May all things great and uplifting find you on this, your very special day.

As you and many others may know, the role of a professor is deeply respected in Japan. We look to our professor to impart not just technical skill and knowledge but also to provide us with moral wisdom to guide us through life. Can anyone who knows you not be aware of how your teaching fulfills these ideals? Who of your students have not been enriched by your lessons in both law and life? The answer, of course, is no-one. We have all been inspired by you to greatness. There is even a former student of yours sitting as a Justice on the Supreme Court of Japan.

What many may not know, however, is that you are so much more than just a professor. Let this one tale tell all of just how great you are. In one of the most desperate times of my life I came to you as an LL.M student at New York University, my wife became pregnant but our visas would expire before her delivery date. She would either have to risk returning to Japan in her advanced condition or over-stay her visa and risk giving birth illegally in the U.S. Like a guardian angel you provided me with work to obtain a visa and for my wife to safely give birth to our second daughter. You saved their lives - and they thrive today.

There is a word in Japanese greater than a professor. It is “onshi” – a term of respect reserved for only the professor to whom we are most deeply indebted and to whom we most deeply revere. Professor Rosenbloom, you are my Onshi.

Happy 80th Birthday, my Onshi Professor Rosenbloom.