Fair Is Fair—How to Assert For and Defend Against Alternative Apportionment
Alternative apportionment presents opportunities and challenges for taxpayers
The concept of apportionment in state taxation is an exception to the rule that life can be unfair. State apportionment must be fair. A wooden reading of a generally applicable apportionment law may not stand if that law yields an unfair result in a particular case. Alternative apportionment exists to…
How CFOs Can Mitigate the Risk of Ransomware
Over the past year, a surging cybersecurity threat has infiltrated the computers of individuals and organizations around the world. Known as ransomware, this type of cyberattack holds sensitive data hostage and then forces victims to pay up to get it back or to stop it from being released or destroyed.… Read more »
After Tax Reform, Don’t Always Think Outside the Box
Reevaluate whether existing foreign investment holdings continue to be tax-efficient and consider reorganizing them
The tax reform act enacted in December 2017 (commonly referred to as the Tax Cuts and Jobs Act or TCJA) significantly altered the landscape of U.S. taxation of foreign investments. Historically, U.S. individuals preferred to own foreign investments directly or through entities classified as partnerships for U.S. federal income tax…
Practical Insights for Combatting New York’s Expansion of Sales Tax Law
The Experts: Zach Gladney and Matthew Hedstrom
Much has been written about the New York State Department of Taxation and Finance’s positions on the taxation of software, software as a service (SaaS), and other software-based services. The critiques have concerned, in part, the department’s guidance on the sales and use tax consequences of cloud computing and other…
TEI Roundtable No. 18: The State Tax Policy Function
Whether it’s part of the tax department or part of government affairs, one thing is for sure—it’s getting more complicated every day
These days state tax policy occupies a greater percentage of the professional lives of many TEI members for a variety of reasons. We wanted to dive deep into this phenomenon, so we convened a roundtable of seasoned practitioners in the field, including Ellen Berenholz, executive director of tax policy at…
Emerging Leader: Brian Mustard
Brian Mustard was working in the audit group at KPMG in Montreal and knew that, in the end, he would not spend his career in audit or accounting. His plan: to go to law school after obtaining his designation and completing his articles. But fate intervened. A position in the… Read more »
Teri Hull
Teri Hull’s interest in tax issues was sparked by dry cleaning. Yes, dry cleaning. Her father owned a dry cleaning business when she was young, and she often tagged along on Saturday mornings. But it wasn’t the back of the store, with all those hangers and clothes, that intrigued Hull;… Read more »
TEI Roundtable No. 17: The View From the Corner Office: What Keeps Them Up at Night?
It’s tax reform, international issues, succession planning, growth versus risk, and dealing with multiple stakeholders and interested parties, including the media—to name just a few
While some might envy the corporate tax vice presidents and senior counsel who occupy the corner office, there’s no denying they have a difficult job, one that is subject to increasing pressures due to changes in tax laws and to increasing media and public interest in tax issues. To get…
BEPS and Allocation of Taxing Rights
The allocation of taxing rights between jurisdictions is a major international tax issue. The current analysis of this issue has largely been set in motion by the OECD/G20 base erosion and profit shifting (BEPS) project and by programs that other international organizations have initiated. It’s important to consider whether jurisdictions… Read more »
Managing Canadian Tax Risk The global tax environment has seen fundamental changes in recent…
Transfer Pricing in Transition Although states experienced significant tax revenue growth during the COVID-19…
The One Big Beautiful Bill Act In July 4, President Donald Trump signed into law the…
Automation in Action: Key Takeaways From the TEI Automation Competition In February, tax professionals from across the country gathered in…
Beyond Automation: Why Having a Human in the Loop Is Critical for Sales Tax Compliance The allure of sales tax automation is undeniable. Many companies,…
TEI Holds Third International Tax Student Case Competition TEI held its third International Tax Student Case Competition at…