International

The New Era of Transparency: Global Trends and Management Strategies
The times they are a-changin’, panelists say

In a particularly engaging session at TEI’s Annual Conference and 75th Anniversary Celebration, panelists discussed the dynamic developments that have resulted in what corporate tax professionals are calling “a new era in transparency.” The session included expert panelists: Sonal Majmudar, a tax partner at Mayer Brown; James Gordon, national co-lead… Read more »

Global Tax Policy and Controversy Trends
Only one thing is certain—they’re not boring

In an engaging and educational Annual Conference session moderated by Cliff Mangano, chair of TEI’s IRS Administrative Affairs Committee, a panel of experts discussed recent developments and trends in global tax policy and controversy. The experts included Scott Frewing, tax partner in the Palo Alto office of Baker McKenzie, who… Read more »

EMEA Chapter Members Report on OECD Stakeholder Meeting

After more than seventy-five years, TEI’s global influence is, by any measure, enormous. An illustrative example is the recent Organisation for Economic Co-operation and Development (OECD) Stakeholder Day on Global Mobility, in which two members of TEI’s EMEA Chapter, Karine Halimi-Guez, vice president and head of tax at Booking.com, and… Read more »

Transfer Pricing Operations and Compliance for In-House Tax Professionals
Even if you’re a smaller organization, don’t assume you won’t be audited or targeted

Transfer pricing has never been more important for in-house tax professionals to address, from compliance and analysis to overall tax planning. However, transfer pricing rules change rapidly and globally, largely as a result of the work of the Organisation for Economic Co-operation and Development (OECD) on the base erosion and… Read more »

How Remote Workforce Programs Trigger Myriad Tax Problems—Part Two
Analyzing taxable presence and nexus issues for employers

The coronavirus pandemic created an explosion in remote workforce programs, some temporary but others indefinite or permanent. Remote work situations can arise in a wide range of settings—some are planned, and others arise well after the fact as a surprise to the in-house tax team. One critical tax issue introduced… Read more »

GloBE Meets GILTI—Part Two
What’s the status of implementation?

Our article, “GloBE Meets GILTI,” which appeared in the January/February issue of Tax Executive, addressed how taxes on global intangible low-taxed income (GILTI) might be allocated. Sadly, the story was already out of date by publication. This follow-up article addresses not the possibilities, but rather what the Organisation for Economic… Read more »

GloBE Meets GILTI
What’s the status of implementation?

When the United States adopted the book minimum tax in July 2022 as part of the Inflation Reduction Act, it became clear that the country was not racing to implement Pillar Two issued by the Organisation for Economic Co-operation and Development in March 2022. But the enactment of the minimum… Read more »

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 »

Technical Corrections to the 2021 Final Foreign Tax Credit Regulations
Correcting the uncorrectable?

As readers are well aware, almost a year ago, on December 28, 2021, the Treasury Department issued final foreign tax credit regulations (hereafter the “final regulations”)1 finalizing the proposed regulations that Treasury had issued the prior year.2 On July 26, 2022, Treasury issued two sets of technical corrections to the… Read more »

TEI Roundtable No. 39: DEMPE Functions and Their Impact on International Taxes
What should we make of a concept encompassing the development, enhancement, maintenance, protection, and exploitation of IP?

At TEI’s 72nd Midyear Conference in Washington, D.C., the Institute conducted a terrific session that focused on the DEMPE functions—development, enhancement, maintenance, protection, and exploitation of intellectual property—as laid out by the Organisation for Economic Co-operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) Project and its impact on… Read more »