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Administrative Guidance, Ethical Standards, and Tax Return Positions
In-house tax professionals must traverse a difficult course
Many corporations currently face tremendous high-value tax uncertainty as a result of the 2017 Tax Cuts and Jobs Act (TCJA), not to mention other longstanding tax risks such as transfer pricing. For some tax executives, these risks constitute familiar waters. For other tax executives, however, navigating these risks is less… Read more »
TCJA—So Many Questions, So Little Time
Law leaves significant open questions for Treasury and the IRS to answer
On December 22, 2017, President Trump signed into law the act commonly referred to as the Tax Cuts and Jobs Act (TCJA, PL 115-97). Like much tax legislation, the TCJA provides a legislative framework but leaves a significant number of questions to be answered by the Treasury Department and the… Read more »
Managing Uncertainty: A Survival Guide to the Tax Cuts and Jobs Act of 2017
TCJA is complex, convoluted, with a dearth of administrative guidance
With the passage of the Tax Cuts and Jobs Act of 2017 (TCJA), tax executives face the most uncertainty in interpreting and applying the tax law they have ever encountered. As is the apparent norm these days, with game-changing congressional legislation, the TCJA was cobbled together quickly, and its clarity… Read more »
Financial Reporting Implications of the Tax Cuts and Jobs Act
Taxpayers need to deal with new realities quickly
U.S. tax reform became a reality on December 22, 2017, when President Donald Trump signed the 2017 tax reform reconciliation act (the Act) into law. The Act represents a fundamental and dramatic shift in U.S. corporate taxation, particularly concerning the taxation of foreign earnings. Since late December, companies have focused… Read more »
Why Wayfair Won’t Matter
Supreme Court case raises ‘substantial nexus’ controversy in internet age, capturing attention of tax specialists—and the public
The state tax community is in familiar territory before the Supreme Court of the United States.1 We are in far less familiar territory, however, having captured the attention of nontax professionals, academics, the American public, and even the president of the United States.2 The eyes of the nation are fixed… Read more »
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 »
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 »
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 »
Your Tax Data Is Ripe for Artificial Intelligence. Are You Prepared?
AI is still evolving, but machine learning is already here
Entrepreneur and Tesla cofounder Elon Musk recently sparked controversy when he labeled artificial intelligence (AI) the “biggest existential threat” to humanity. On the flip side, according to Sandhya Venkatachalam of Centerview Capital Technology, AI can be used to fundamentally rethink how we solve the world’s problems and has the potential… Read more »
Indirect Taxes, Canada: Impact of Delivery Terms
Effect is significant on application of GST/HST on imports, exports, and sales
Canada imposes a five percent federal value-added tax called the goods and services tax (GST), which applies to the supply of most goods and services in Canada and to imports of most goods into Canada. Five Canadian provinces (Ontario, Nova Scotia, New Brunswick, Prince Edward Island, and Newfoundland and Labrador)… Read more »


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