Features
Part III: Moving to the BEAT
Don’t look now, but there’s a new minimum tax for U.S. corporations
The Tax Cuts and Jobs Act of 2017 brought about the most sweeping U.S. international tax reforms in the past 30 years.1 One of those reforms was the base erosion and anti-abuse tax, which is also known as the BEAT.2 The BEAT is intended to prevent large U.S. corporations from… Read more »
Part II: GILTI, FDII, and FTC Guidance and International Tax Planning
How to decipher this complex stew, replete with interesting ingredients
Prior to tax reform, multinational businesses often had similar strategies with respect to outbound international tax planning. Given the high U.S. corporate tax rates and worldwide system of taxation, many businesses sought to earn and keep profits offshore to defer U.S. tax. When it was important to repatriate profits, foreign… Read more »
Part I: The Graphic Guide to Section 163(j)
A visual breakdown of this important aspect of the TCJA
As children, we learned new and difficult concepts, such as our first words, by associating them with pictures. Who could forget the Dr. Seuss classic Hop on Pop? In this article, we take you back to your childhood by offering a series of pictures to simplify the most significant aspects… Read more »
TEI Roundtable No. 23 Transitioning to a New Job
Let’s face it, it’s a weird mix of excitement and anxiety
For anyone, in any field, finding and transitioning to a new job is an intense experience—somewhat exhilarating, somewhat scary. We wanted to find out what the experience was like for seasoned TEI members, two of whom recently transitioned into new jobs: Louis Mestier, now vice president of tax for Eldorado… Read more »
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 »
TEI Roundtable No. 22: Developing a TCJA Checklist
International issues, software selection, and involvement of tax technologists all play key roles in a complicated process
The Tax Cuts and Jobs Act is not “new” anymore. But compliance with an ever-evolving set of regulations and guidance is still on the front burner for corporate tax professionals—and is likely to stay there for quite a while. As with so many tax issues, the best way to ensure… Read more »
Tax Legislation in the 116th Congress—What to Look For
Ways and Means Committee hearings on TCJA may offer advocacy opportunities
Conventional wisdom says that Wall Street likes divided government, but should tax directors feel the same way? Now that the new Congress has been sworn in and is beginning its work, businesses must attempt to determine what the prospect is for tax legislation in the 116th Congress with a Democratic… Read more »
Taxable Nexus: Moving Toward an Economic Approach
Corporate tax professionals might consider OECD approach
In this article we discuss the global trend toward taxing foreign companies with significant business abroad that have managed, by dodging local permanent establishment requirements, to remain outside the tax net in the countries where they do business. In particular, we discuss the recent trend whereby taxing authorities have significantly… Read more »
Tax Avoidance vs. Tax Evasion
What every tax director needs to know about criminal tax fraud
Reducing tax liability is a top priority for every corporate tax department. But that priority must be tempered by tax compliance obligations. Increasingly complex business relationships and transactions—often accompanied by increasingly complex tax planning—can leave even the most sophisticated tax practitioners wondering how the Internal Revenue Service will react to… Read more »
TEI Roundtable No. 21: TCJA Implementation: A View From the Trenches
Dealing with landmark legislation takes a special kind of planning
Tax Cuts and Jobs Act (TCJA) implementation, compliance, and planning is a work in progress. How are tax professionals in the trenches dealing with this landmark legislation? To find out, we convened a roundtable of experts including Stephanie Kuykendall, vice president and general tax counsel at Shell Oil Company; Jason… Read more »
State and Local Tax Implications for a Remote Workforce State and local tax issues related to remote workforces have…
Tax’s Role in Tech Transformation As tax experiences its own transformation with technology, companies are…
Key Challenges and Opportunities for Tax Directors in a Tightening Economy Navigating a tightening economic cycle—characterized by prolonged high interest rates…
Question: How Can Companies Take Advantage of Digital Assets With No Tax Impact? Digital-asset-based loyalty and reward programs allow companies to create a…
The Rise of the Excise Tax In August 2022, Public Law No. 117-169—commonly called the Inflation…
TEI Roundtable No. 48: AI Implementation in Today’s Tax Landscape As artificial intelligence (AI) gains traction throughout the business world,…