Features

Nuts, Bolts, and Nuances of the Competent Authority Process
Relief is provided in most cases, but pitfalls and new issues are multiplying

The competent authority procedure is a dispute resolution mechanism available to taxpayers facing cross-border disputes under an applicable tax treaty. The taxpayer may invoke this procedure to require the tax administration’s competent authority function to “endeavor” to resolve the dispute by “mutual agreement” with its counterpart in the treaty partner… Read more »

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Tax-Efficient Supply Chain in Shadow of Tax Reform
GILTI, FDII, and BEAT: they’re not just acronyms—they require reassessing tax consequences of existing supply chain structures

For the past quarter century the same legal framework and economic incentives have driven how multinational corporations structure their supply chains. Relatively high U.S. corporate rates incentivized companies to locate valuable assets and operations in lower-taxed jurisdictions; the United States’ worldwide tax regime incentivized retaining and reinvesting those earnings outside… Read more »

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Anatomy of a Multijurisdictional Dispute
Recent tax reform presents additional considerations

Demands on tax executives have never been higher. Whereas international tax rules have always been complex, the Organisation for Economic Co-operation and Development’s Base Erosion and Profit Shifting (BEPS) Action Plan and now U.S. tax reform introduce new levels of complexity and uncertainty. At the same time, sensational media coverage… Read more »

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TEI Interview: John Koskinen
Former IRS commissioner gives TEI members an up-close look at why budgetary constraints presented a major challenge during his tenure—and still do

John Koskinen served as IRS commissioner for almost four years before leaving office in November 2017. As IRS commissioner, Koskinen dealt with thorny issues, including antiquated technology, the growing importance of international tax issues, and, of course, budget constraints. Tax Executive was granted one of the first interviews with Koskinen… Read more »

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Effective NOL Planning in Light of Tax Reform
Can your company unlock the value of net operating loss carryforwards to reduce future taxable income?

Under current tax rules, a corporation can generally carry back a net operating loss (NOL) to the two preceding taxable years and carry it forward up to the twenty taxable years following the loss to offset 100 percent of federal taxable income and ninety percent of the alternative taxable income.… Read more »

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Pros and Cons of Voluntarily Disclosing Past Wrongs
To disclose or not to disclose, that is the question

Hamlet’s thoughts weighed heavily upon him. Should he suffer the slings and arrows of outrageous fortune, or take arms against a sea of troubles? For the young Prince of Denmark seeking to avenge his father’s death, the choice was action or inaction, and ultimately life or death. Fortunately, most tax… Read more »

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TEI Roundtable No. 16: Diversity and Inclusion in the Tax Industry
A growing commitment to a policy with clear-cut business benefits

Workforce diversity is a concern in every industry, and tax is no exception. But what issues are currently relevant, and is there a business rationale for increasing diversity? To explore this topic further, Tax Executive convened a roundtable discussion group composed of diversity leaders in the industry, including Margie Dhunjishah,… Read more »

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2017 Annual Report

Institute Officers Audited Consolidating Financial Statements Tax executives Institute, Inc. and TEI Education Fund June 30, 2017 Independent Auditor’s Report To the Board of Directors Tax Executives Institute, Inc. and TEI Education Fund We have audited the accompanying consolidating financial statements of Tax Executives Institute, Inc. and TEI Education Fund… Read more »

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Addressing New Federal Partnership Audit Rules and Reporting of Federal Adjustments to States
Bipartisan Budget Act of 2015 provides opportunity for greater uniformity

In recent years Tax Executives Institute, Inc. (TEI), has met with various state organizations and revenue departments to encourage standardizing the rules for reporting federal audit adjustments. These efforts have been fruitful but have even greater potential for success with the passage of the Bipartisan Budget Act of 2015 (BBA),… Read more »

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Congress Pivots From Health Care to Tax Reform
Ultimate outcome on taxes in 2017 still up in the air

Benjamin Franklin is frequently credited with saying that there’s nothing certain in life except death and taxes. I would suggest an addendum to this adage for 2017: another certainty is the steady drumbeat of news stories claiming that tax reform is imperative and imminent. Years of hearings, commissions, white papers,… Read more »

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