Subin Seth is a Senior Counsel with the IRS, Office of Associate Chief Counsel (International). He focuses primarily on issues involving inbound international taxation, including withholding and reporting on payments to foreign persons. He has worked on various forms of published guidance, including regulations that coordinate chapters 3 and 4 of the Code, provide withholding requirements related to sections 305(c) and 1446(f), and implement the international aspects of the centralized audit partnership regime (BBA). 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.