Features
TEI Roundtable No. 27: State Tax Issues, 2019–2020
In general, taxpayers want more guidance
In the last few years, there’s been a discernable focus on federal tax issues in the wake of the passage of the most comprehensive tax reform package in three decades. But much of the action is taking place in state legislatures and state departments of taxation. We wanted to get… Read more »
Looking Ahead: Predictions on Upcoming State Tax Legislation
Key drivers are state economy and gubernatorial election cycle
With the turn of the new year and a new decade, it is only natural to try to predict what state tax legislation may become law in 2020. Many factors can affect the nature and pace of state tax legislation, but perhaps the two leading drivers are the state economy… Read more »
Don’t Throw Out New Jersey Throwout Cases
Why? It’s really a national issue
The New Jersey throwout wins are more nationally relevant than ever, even though New Jersey repealed the throwout provision in its Corporation Business Tax Act nearly a decade ago. “Throwout” takes its name from the requirement that receipts be removed from (or “thrown out” of) a company’s sales factor denominator… Read more »
Addressing Proposed Section 382 Regulations in Current M&A Transactions
These revisions will impact deal terms and valuation
In September 2019, the Internal Revenue Service (IRS) and the Treasury Department issued proposed Section 382 regulations that, when finalized, would significantly reduce the value of net operating losses (NOLs) following Section 382 ownership changes, including those that occur in connection with mergers and acquisitions.1 In particular, the proposed regulations… Read more »
Intersection of National Security With M&A: The Committee on Foreign Investment in the United States
Why does the United States have laws that regulate M&A activity from a national security perspective, and why are those laws now getting more attention?
Once a sleepy, shadowy backwater of the federal government, the Committee on Foreign Investment in the United States (CFIUS)—the U.S. government’s principal mechanism for screening foreign investment to assess and address its potential impact on U.S. national security—has hit the big time. In the last eighteen months, Congress passed sweeping… Read more »
A More Collaborative Tax Controversy Approach?
Strategies for Exam and Appeals
Tax executives are familiar with the scenario: Internal Revenue Service examiners are in the building and are beginning to issue information document requests (IDRs) on routine and sensitive issues. One typical taxpayer response is to go on the defensive. This approach includes not voluntarily identifying issues and transactions; responding to… Read more »
A Tax Executive’s Guide to Spin-offs: 10 Things You Won’t See in Section 355
Advise board and officers to be careful about certain negotiations or public statements during pendency of the spin
Behind the closed doors of a corporate boardroom somewhere in America, the directors of a publicly traded company are discussing the future of their business. For many years, the company has operated two major divisions that have gradually diverged over time. These divisions (having the remarkably original names Business A… Read more »
Data Privacy at a Crossroads
As privacy laws proliferate globally, the IRS expands its ability to seek and obtain taxpayer data
In recent years, two important legal developments have accelerated and are currently on a collision course. The first is the rapid proliferation of data-privacy laws across the globe. As explained below, these laws—such as the European Union’s recently enacted General Data Protection Regulation (GDPR)—broadly prohibit unauthorized collection and transmission of… Read more »
Valuation Perspectives From Around the World
Increased analysis within financial reporting comes with increased levels of analysis required for tax reporting
The valuation of entities and assets is under greater scrutiny by tax authorities. Although valuation standards for tax purposes have generally lagged behind those for book purposes, new global standards require increased data, analysis, and support. This article will briefly review the developing and changing landscape and provide some practical… Read more »
Funds With Benefits: Investing in Qualified Opportunity Zones
Are you up to date on the two sets of IRS-proposed rules on QOZs?
The Tax Cuts and Jobs Act1 created qualified opportunity zones (QOZs) to spur economic development throughout the United States by providing tax benefits to investors who make qualifying investments in these zones. Thousands of population census tracts have been designated as QOZs. Under the QOZ program, taxpayers who timely roll… Read more »
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…
Preparing Now for 2025 Tax Legislative Activity Editor's note: This article was finalized prior to President Donald…
TEI to Comment on New Proposed Section 987 Regulations The US Treasury Department and Internal Revenue Service published new…
How Tax Insurance Can Be a Valuable Tool for Managing Transfer Pricing Risk in 2025 and Beyond Heightened regulatory scrutiny around the world has made transfer pricing…
TEI Welcomes New Staff, Promotes Team Member Erica Larkin Erica Larkin joined TEI in November as the…