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TEI Roundtable No. 40 Foreign Tax Credit Regulations
Are you up-to-date?

For almost four decades, the foreign tax credit regulations have established a three-part net gain requirement for determining when a particular foreign levy is an income tax. Now, things have changed. We assembled a panel of knowledgeable tax practitioners in the space to discuss how these changes came about and… Read more »

Managing Corporate Foundation Risk
What role do in-house tax professionals play in advancing charitable objectives?

Causes worthy of support are plentiful, and new ones seem to appear daily. How a company responds to societal needs is more important than ever. More than 2,800 corporate foundations are estimated to exist in the United States.1 Many companies are moving away from traditional or responsive models of philanthropy… Read more »

Interview With IRS Deputy Chief Information Officer Kaschit Pandya
IRS and TEI working group coordinates efforts to optimize IRS technology

To keep current on tax issues, TEI members always like to hear directly from top Internal Revenue Service officials. So, we were thrilled when Kaschit Pandya, deputy chief information officer at the IRS, accepted our invitation to be interviewed by Brian Kaufman, vice president and tax counsel at Capital One… Read more »

You’ve Been Served: Defending Against a State Tax Class Action
Are you prepared for this rising threat to your business?

An email comes from the general counsel: your company has been sued by a customer who alleges that the company systematically overcharges sales tax.1 The complaint—the legal document that starts the lawsuit—contains multiple counts for various violations of state statutes and common law doctrines and demands damages, attorney’s fees, and… Read more »

Obtaining IRS Refunds: Procedures and Strategies
It’s rarely as simple as you think

Uncertainty in tax law is reaching unprecedented levels. In the past four years, taxpayers have managed dramatic tax reform, pandemic-fueled emergency tax legislation, rafts of new Treasury Regulations (and accompanying challenges to some regulations), and increased aggressiveness by certain tax authorities. Tax departments now must be nimbler than ever as… Read more »

TEI Roundtable No. 37: Lessons Learned From TCJA Implementation
What are the implications for Biden’s proposals?

This roundtable was conducted on October 27 as the closing plenary session of TEI’s 76th Annual Conference in Florida. The session, Lessons Learned From TCJA Implementation and Implications for Biden’s Proposals, featured four distinguished panelists who shared their perspectives on the practical implementation and administration of business tax reform legislation:… Read more »

The Changing Landscape of Indirect Tax
Guidance on emerging challenges in state and local indirect tax in the wake of COVID-19

The indirect tax landscape has changed rapidly in response to the COVID-19 pandemic. If the Supreme Court’s decision in South Dakota v. Wayfair in 2018 created a new playing field, complete with new marketplace facilitator guidance, the global pandemic has moved the goalposts. In this demanding environment, what is the… Read more »

ESG Tax Transparency
You might want to check out BRT’s statement signed by 181 CEOs

In years gone by, business looked primarily to increasing shareholder returns, paying less attention to how their business practices affected the environment and society. For many, the primary concern in supply chain design was cost, with little inquiry into how supply chain partners conducted business. But more and more, such… Read more »

Who Is Interested in My Request for Interest?
Procedural missteps can risk taxpayers’ pursuit of overpayment interest from the IRS

The law is clear: “If a taxpayer overpays its taxes, the IRS owes the taxpayer interest on that amount.”1 This obligation certainly characterized the Internal Revenue Service’s 2020 fiscal year, in which the IRS paid more than $3 billion of overpayment interest to taxpayers.2 This figure is just the latest… 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… Read more »