Subin Seth is a Senior Counsel with the IRS, Office of Associate Chief Counsel (International), focusing primarily on issues involving inbound international taxation, including withholding and reporting on payments to foreign persons and the interpretation of treaties. He has worked on various forms of published guidance, including regulations coordinating chapters 3 and 4 (FATCA) of the Code, providing withholding requirements related to sections 305(c) and 1446(f), implementing the international aspects of the centralized partnership audit regime (BBA), and providing rules for foreign investment in opportunity zones. He has previously served as an attorney with the Corporate and the Large Business and International divisions of the Office of Chief Counsel. He received his J.D. from the University of Florida and his L.L.M. from New York University.