Bibiana A. Cruz
About the Committee
Hello, and Welcome! Thank you for taking the time to visit the website of the U.S. Activities of Foreigners and Tax Treaties ("USAFTT") Committee of the ABA Tax Section. USAFTT is committed to advancing the education of the ABA Tax Section’s members with respect to the U.S. taxation of foreign persons and with regard to U.S. tax treaties. We also actively comment on legislation, Treasury Regulations, and other guidance pertaining to these subject matter areas.
We are always keenly interested in recruiting new members and welcome attorneys of all experience levels and backgrounds. We pride ourselves on the diversity of our committee membership and on the broad participation of our members. Our Committee holds a “business meeting” at each of the three annual meetings of the Tax Section. At these meetings, we identify topics for upcoming panels, discuss comment projects, and address other matters of interest to our members. We urge all of our members to join us at these meetings and become an active part of this process. We want to hear your ideas and to solicit your involvement in our upcoming panels and in valuable comment projects. This is an extremely active time for comment projects relating to tax reform, so this is truly an extraordinary chance to get involved and have an impact on future guidance.
Participating in the Committee also is a great way to expand professional relationships and personal friendships. In addition to our panels and our business meetings, we join the Tax Section’s other international tax committees in holding a joint dinner on the Friday evening of each Tax Section meeting. The dinner provides a terrific opportunity for informal networking with a diverse, international group of peers who share an interest in international tax.
In conjunction with our partners in the Foreign Activities of U.S. Taxpayers Committee, we also have organized a committee for Young Lawyers of International Tax ("YLIT") and encourage junior lawyers who have an interest in our Committee to participate in YLIT activities.
Who We Are
The Committee on U.S. Activities of Foreigners & Tax Treaties principally focuses on the U.S. federal income tax consequences of, and planning opportunities for, U.S. investments and U.S. activities by foreign individuals and entities and the repatriation of income and capital from the U.S. to those foreign persons. The committee is interested in bilateral income tax treaties and information exchange agreements between the U.S. and foreign nations and the competent authority assistance mechanisms in such treaties and agreements.
The Committee maintains a high level of timely and sophisticated panel programs at each of the three Committee meetings during the year. It sponsors task forces to address U.S. tax policy issues affecting foreign corporations investing in the U.S. and nonresident, non-citizen individuals. The Committee prepares timely comments in connection with anticipated tax legislation and proposed regulations.