Tales From the California Tax Controversy Trenches: Navigating FTB Sales Factor Audits
Proper planning can lead to a successful audit— or at least a more tolerable one
One of the California Franchise Tax Board’s1 guiding principles is to “administer the Revenue and Taxation Code . . . and be vigorous in requiring compliance with the law.”2 Our decades-long experience with California tax controversy provides perspective on the FTB’s vigor for compliance. This vigor is never more apparent…
Payroll Tax Credits and PPP Interplay: Enter the IRS Employment Tax and SBA PPP Loan Audit
It’s time to have a conversation about audits, specifically the Internal Revenue Service employment tax audit and the Small Business Administration PPP loan forgiveness audit. Regardless of what industry or sector includes your organization, the COVID-19 pandemic forced all employers, big and small, to deal with new employment issues. Fortunately,… Read more »
IRS Appeals Conferences During the Pandemic
The Expert: Bill Colgin
A few months after COVID-19 closed Internal Revenue Service buildings and employees were sent home to work remotely, the reality of a backlog of pending matters led IRS Appeals to awaken and move forward again. Appeals officers, Exam teams, and taxpayer representatives tentatively began holding Appeals conferences and meetings using…
Emerging Leader: Brian Kaufman
Brian Kaufman is very familiar with the aphorism, “like father, like son.” Kaufman’s father was a tax accountant for thirty-five years at Arthur Andersen. Because of that, Kaufman says, he had absolutely no desire to go into tax. “It seemed so boring and esoteric. I was really set on being… Read more »
TEI Issues Guideposts for Tax Policy in 117th Congress
Welcome to the latest installment of Advocacy Agenda, a periodic column that aims to share select insights and observations of interest to TEI members about the tax policy advocacy environment in Washington, D.C. Over the past three years, the historic tax reforms enacted in Public Law 115-97, colloquially known as… Read more »
Tax Rate Modeling in the New World of US International Tax
Foreign branch versus CFC and the GILTI high-tax exclusion are two essential modeling imperatives
The world is getting smaller and more complex. National economies are more integrated globally, but national deficits and the need for tax revenues are driving unilateral measures. The original objective of the base erosion and profit shifting (BEPS) project has been described as ensuring that profits are taxed where economic…
Emerging Leader: Agnieszka Samoc
Agnieszka (Ag) Samoc likes puzzles. And for Samoc, practicing tax is a lot like solving puzzles. Her education gave her the requisite tools, such as legal analysis methods and quantitative abilities through accounting, that enabled her to solve tax puzzles effectively. “And then, right when I was graduating college in… Read more »
International Tax Competitiveness Update
Every country’s tax code is unique, but how do experts define and rank competitiveness around the globe? Each year, the Tax Foundation pulls together its evaluation of how countries in the Organisation for Economic Co-operation and Development structure their tax systems, titled the International Tax Competitiveness Index (ITCI). The index… Read more »
TEI Advocacy Update
TEI’s standing committees continue their excellent advocacy work across the globe. Copies of TEI’s submissions can be found at www.tei.org/advocacy. To get involved in TEI’s advocacy efforts, please reach out to our committee chairs or any member of TEI’s legal staff. TEI’s Tax Reform Task Force Outlines New Guideposts for… Read more »
What a Difference a Year Makes
As I write this column, I can’t help reflecting on what was happening a year ago at this time. We learned that the COVID-19 virus had triggered a pandemic, we were uncertain of when or how we could resume working in an office or how children could attend schools, and… Read more »
Optimizing Your Tax and IT Stack Tax leaders, tax technologists, chief financial officers (CFOs), and chief…
An Overview of the EU Public Country-by-Country Reporting Rules The European Union (EU) has long been at the forefront…
Optimizing Tax Through Structured Data Storage and Data Pipelines In today’s fast-paced digital business environment, tax departments are under…
Renewable Energy Tax Credits After the Inflation Reduction Act Following the the 2024 US general election, with Donald Trump’s…
TEI Roundtable No. 49: A Look at the TCJA in 2025 Editor’s note. This conversation was recorded in August, prior to…
Inequitable Barriers to Equitable Apportionment Every state that imposes a corporate income tax requires multistate…