Background
Cole, Robert Theodore was born on March 16, 1932 in Brooklyn. Son of Harold I. and Bella (Weissman) Cole.
Cole, Robert Theodore was born on March 16, 1932 in Brooklyn. Son of Harold I. and Bella (Weissman) Cole.
Bachelor of Science in Economics, University Pennsylvania, 1953. Bachelor of Laws magna cum laude, Harvard University Law School, 1956. Diploma in law, London School of Economics, 1958.
Worked at Alston & Bird Limited Liability Partnership (Atlanta, Georgia) specializing in International Law, Taxation Law. Admitted to the bar, 1956, New New York 1972, District of Columbia.
1989, United States.
Supreme Court (Not admitted Georgia). Beta Gamma Sigma; Delta Sigma Rho. Editor, Harvard Law Review, 1954-1956.
Author: "Tax Aspects of Foreign Direct Investment in the United States," Volume 6, United States.
Department of Commerce Report to the Congress on Foreign Direct Investment in the United States, 1976. Company-Author: "Highlights of the New United States.-United Kingdom Income Tax Treaty," The Tax Adviser, October, 1976.
"German Corporate Tax Reforms and Its Effects on United States. Investment," The Tax Adviser, May, 1977.
"Mutual Agreement-Procedure and Practice," Cahiers de Droit Fiscal International, 1981.
"The Appeals Route to Competent Authority?" Tax Management International Journal, January, 1984. "Review Ruls. 84-152, 84-153 and GCM 37940 Depart From United States. Treaty Obligations," with Steven A. Musher, Tax Management International Journal, August 9, 1985.
"Competent Authority Procedure As A Solution To Transfer Pricing DisputesThe United States.
Experience," International Taxation, Tokyo, April, 1986. "Working With the Section 482 White Paper," The Tax Executive, Winter, 1989.
"New Internal Revenue Service Recordkeeping and Summons Requirements for Enforcing United States Transfer Pricing Rules in Foreign-Owned Situations," Intertax, 1990/2. "Proposed Section 6038A Regulations," The Tax Executive, January-February, 1991.
"New Competent Authority Procedure Allows for Increased Flexibility," The Journal of Taxation, June, 1991.
Company-Author: "Advance Pricing Agreements Provide a Safe Harbor," Journal of International Taxation, May/June, 1991. "Section 6038A recordkeeping for foreign-owned groups - a new requirement for doing business in the United States - practical approaches to compliance," Intertax, 1991-1992. "United States: Proposed Transfer Pricing Regulations Under Section 482 of the Internal Revenue Code," Bulletin for International Fiscal Documentation, Volume 46, Number.
6, June 1992.
"Complying with United States. transfer pricing rules," Corporate Finance and Global Investor, November 1992. "An APA: Now Is the Time to Consider this Option," Tax Management Transfer Pricing Special Report, Volume 1 Number. 25, April 28, 1993; "Exchange of Information and Assistance in Tax Collection (Participant I), "Tax Management International Journal, Volume 12 Number.
23, December 9, 1994.
"Views of Foreign Tax Officials on the United States. Transfer Pricing Regulations - An American Introduction," Tax Management Transfer Pricing Special Report, Volume 3 Number.
16, December 14, 1994. "Exchange of Information and Assistance in Tax Collection (Participant II)," Tax Management International Journal, Volume 24 Number.
1, January 13, 1995; "United States.
Internal Revenue Service Proposes to Update Competence Authority Procedures," with J. East. Croker, Junior, Tax Notes International, February 13, 1995. "Advance Pricing Agreement Practice Under the New Rules," 83 J. Tax" n 215 (October 1995). Attorney, United States.
Treasury Department, 1967-1973.
International Tax Counsel, United States. Treasury Department, 1971-1973.
Member, Tax Committee, 1984 and Vice Chair, Tax Committee, 1990-1995, National Foreign Trade Council. Fellow, American College of Tax Counsel.
Member: District of Columbia Bar.
Captain United States Air Force, 1957-1959. Fellow American College Tax Counsel. Member of New York State Bar Association, Association Bar City New York, National Foreign Trade Council (vice-chair tax committee 1989-1995), HarvardClub (New York City).
Married C. Margaret Hall, October 25, 1959. Children: Elizabeth, Tanya, Judith Amy.