Jeremiah Coder is a tax policy adviser at the Organisation for Economic Co-operation and Development (OECD), with prior experience in private practice and as a contributing editor at Tax Analysts.
Q: I’m here with Jeremiah Coder from the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes. Thank you, Jeremiah, for agreeing to be interviewed for the Tax Times.
A: Great talking to you, Tom.
Q: Jeremiah, how did you get into tax?
A: I’d known for a very long time, since a teenager, that I was interested in tax. A good family friend was an accountant and based on his encouragement, I decided to follow that same route. So I got an accounting degree. But as part of that process I had a fascinating business law professor who really made the law seem fun. I decided to keep my tax focus, but in the legal realm, so I went to Notre Dame for my J.D. From there I’ve had a very unique career path.
Q: Let’s talk about that path.
A: Sure. After law school I went to Washington, D.C. to clerk for Judge Mark Holmes at the U.S. Tax Court, which was a very formative experience of seeing tax play out in a wide variety of circumstances. As Judge Holmes would tell his clerks, tax cases are not really so much about tax, oftentimes, but just integrated stories in the larger unfolding of real life. At the Tax Court, you see everything, from very small individual innocent spouse cases all the way up to intricate technical issues in large corporate cases, with all sorts of fun procedural twists. So it was a great formative experience. After that, I wasn’t sure what I wanted to do, but because I enjoyed writing so much, I went to Tax Analysts, which offered me the chance to dive into both technical and policy questions confronting the tax profession. I was there for a number of years as a contributing editor. I think one of the best things that came from that experience was developing such a great network of tax professionals across the U.S.
Tax Analysts provided me a unique opportunity to be a tax generalist. You never knew what issues would bubble up each day. It could be tax accounting one day to international tax the next, from employment tax to fuel tax issues. It really keeps you on your toes, having to write under a daily deadline, to quickly shift topic areas, and to quickly adapt to new issues. You have to communicate to the general public, but you also have to be technically correct because readers rely on you to communicate important news and trends.
Q: Do you have any good stories from your time at Tax Analysts?
A: One of the most unique experiences was going to the Supreme Court to cover a couple of tax cases that the Justices heard during my time, which is generally rare. Seeing that dialogue in person upfront from the reporter’s gallery, where you’re not allowed anything but a pad and pen. It’s quite an intense experience trying to capture the Justices’ quick-fire questioning and the responses from the arguing attorneys. It was very interesting to see them all at work during oral arguments.
Q: So then from Tax Analysts, you moved into private practice.
A: I appreciated the opportunity to have a wide range of client matters that allowed me to further develop my technical skills as a lawyer, especially in procedural issues. I enjoyed the continuing mentorship and dialogue with colleagues across the U.S. I don’t think many people understand the friendliness of tax lawyers in our community. It takes everyone sharing their experiences of how to confront issues, how to address unique problems that clients face. Being able to share one’s experience and learn from others—both new and old in the profession—is key.
Q: And you’ve been coming to Tax Section meetings for a while, initially as a clerk, then as a journalist, and now as a member. How has the Section helped you build your professional network and understanding over time?
A: My first ABA meeting was in 2006 and I’ve attended most of them since then. The Section is critical in bringing together professionals who are really interested in the issues that confront the tax community. Even though tax can often seem, from the outside, very technical and narrow-minded, there’s great breadth in the tax profession. So having meetings such as the three Section meetings each year gives us that opportunity to network and really find out what’s going on in other areas of tax. Again, if you have a fairly general tax practice, you never know what types of issues are bubbling up with your friends in other areas. Having an eye on current developments and also a network of colleagues when you are confronting something for the first time or just need to bounce an idea off another practitioner is very helpful. The variety of ways to be engaged in the Section is limitless, from speaking on panels or helping writing comment letters that are really appreciated and listened to by government officials. Again, it’s the fundamental engagement with fellow practitioners; it’s all rewarding and it fills a critical role, regardless of where you are in your career.
Q: So you moved from private practice to the OECD, which is a mystery to most of us. Can you tell us what the OECD is and what you do there?
A: Yes. Well, the OECD is an international organization of member governments that was founded after the Marshall Plan following World War II. It’s largely focused on economic development issues, but that plays out in a host of areas. Within the OECD, I work for the Global Forum on Transparency and Exchange of Information for Tax Purposes, which is housed in the OECD Center for Tax Policy and Administration. There are so many important issues being worked on in CTPA, but I primarily work on exchange of information issues. Right now that involves giving lots of technical assistance to developing countries, helping them to develop capacity for the exchange of tax information -- both exchange of information on request, which is the traditional process, as well as the fairly new automatic exchange of financial account information under the Common Reporting Standard. The work has many aspects, such as developing legislation that needs to be put in place in the legal framework, ensuring adequate supervision, as well as developing capacity for their tax administration operations. I had really wanted to get back into the policy realm, and being here it has been very rewarding to have the opportunity to travel the globe and work one-on-one with jurisdictions, to see the progress being made for their domestic revenue collection capabilities that in turn funds economic progress in their own territories.
Q: And a lot of our members will be jealous to learn that you do all of this from Paris.
A: Paris, obviously, is a great place to be. The food and the culture there is quite an experience.
Q: Does your seat in Paris give you a fresh perspective on trends in international tax administration? Especially, as those trends might affect us here in the United States?
A: Well, certainly, anyone reading the tax press will know that there’s a lot going on in terms of international tax policy, with quite a lively debate in terms of the nature of unilateral versus multilateral approaches to international tax. At the OECD, supporting the development of common agreed frameworks that countries can use to come together to jointly approach some of these very difficult issues is very hard work, but rewarding. Obviously, there’s a debate as jurisdictions try to understand whether certain problems can be tackled on an agreed approach globally, versus whether perhaps political considerations or any local needs are forcing them to act independently. So I think we’ll see, both in 2019 and going forward, a lot of continued discussion as jurisdictions continue to engage, which is a great thing. We’ll all be keenly interested in seeing the outcomes.
Q: Jeremiah, any last thoughts as we conclude this interview?
A: I’d just reiterate the benefits of really being engaged in the Tax Section and the tax profession generally. My career has been propelled by a number of very good mentors who took a keen interest in me and helped me succeed professionally and supported my interest in policy, in part through Section activities, and so I encourage everyone to use the Section for those same opportunities.
Q: That’s great. Well, thank you, Jeremiah.
A: Thank you. ■