Features
TEI Roundtable No. 48: AI Implementation in Today’s Tax Landscape
A panel from TEI’s Tax Tech Seminar reconvenes to keep the conversation going on the evolution of artificial intelligence in tax
As artificial intelligence (AI) gains traction throughout the business world, tax is in the thick of it, aiming to take advantage of AI’s benefits while navigating the attendant complexities. At TEI’s Tax Technology Seminar held this spring in Orlando, one session spoke to those issues at length—an engaging conversation and… Read more »
Pillar Two and IRS Notice 2023-80
Offering clarity on QDMTTs and top-up taxes
Internal Revenue Service Notice 2023-80 (hereinafter “the notice”) provides the US government’s view on the foreign tax credit treatment of Pillar Two top-up taxes and makes a clear distinction between qualified domestic minimum top-up tax (QDMTT) and the extra-jurisdictional top-up taxes imposed by an income inclusion regime (IIR) and the… Read more »
State and Local Tax Implications for a Remote Workforce
As remote work becomes more common, withholding and nexus are among key considerations
State and local tax issues related to remote workforces have existed for many years. However, the pandemic—with the attendant drastic increase in employees working from home or elsewhere—has intensified these issues and brought them to the forefront of taxpayers’ attention. The remote work trend continues even as we emerge from… Read more »
Brief Overview of What the Pillar Two Directive Means for Multinational Companies
Pillar Two’s inconsistent adoption by EU member states could complicate an already intricate system of domestic and EU laws that businesses must navigate
Editor’s note: This article was written prior to the OECD’s new administrative guidance on Pillar Two, released June 17. This article examines two central points for multinational enterprises as they grapple with the complexities and novelties of Pillar Two. We first address nuanced interpretations of various points of guidance and… Read more »
Tax Valuation Considerations for M&A Transactions
A close look at purchase price allocations, Section 382 limitation calculations, tax receivable agreements, and more
Public corporations, private equity-backed portfolio companies, and privately held companies often look to mergers and acquisitions (M&As) to drive growth and shareholder value. However, pursuing M&A-driven growth may be complicated, since companies must comply with ever-evolving financial and tax reporting requirements, deal with increasing financial audit and tax authority scrutiny,… Read more »
Your Complete Pillar Two Playbook
Follow these steps to tackle complexity, allocate resources, automate new processes, and more
Today’s resource-challenged tax departments often find it necessary to focus on what’s most critical. Although the release of the Pillar Two model rules captured attention, its adoption remained uncertain until things abruptly changed at the end of 2022, when three events occurred: The European Union unanimously agreed to a directive… Read more »
Sales Tax and the M&A Process
Understanding the entire journey—from diligence through post-transaction
Mergers and acquisitions (M&As) play an active role in the corporate landscape, facilitating growth, consolidation, and strategic realignment among businesses. Companies often include M&A activity in their short-term and long-term strategies. To successfully navigate M&As, tax directors and chief financial officers identify areas that tend to present pitfalls that can… Read more »
TEI Roundtable No. 47: My Tax Journey, Part Two
Tax professionals share insights into their unique journeys and roles
In this continuation of last issue’s Roundtable, participants from TEI’s 2023 Annual Conference panel, also titled “My Tax Journey,” discuss work-life balance, handling personal and professional crises, and the next generation of tax experts. The panel includes Josephine Scalia, head of tax at Nestlé Health Science and senior vice president… Read more »
Purchasing Clean Energy Tax Credits
What corporate tax teams need to know about prevailing wage and apprenticeship requirements
The Inflation Reduction Act of 2022 (IRA) greatly expanded energy-related federal income tax credits and created Internal Revenue Code Section 6418, which allows eligible taxpayers to transfer, or sell, certain clean energy tax credits to unrelated parties for cash. One key area of due diligence when purchasing a tax credit… Read more »
The SALT Team of the Future
An income tax perspective on the evolution of work environments
To respond to rapidly changing state and local tax (SALT) developments, this article envisions how a well-balanced SALT team can serve the needs of a large multistate business. It is instructive to look at how things, from a tax perspective, used to run in office settings back in the day,… Read more »
Prepare for Public Country-by-Country Reporting With public country-by-country reporting (CbCR) on the horizon, companies with…
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…
Who Is the Customer? Compared to the complexity of cost-of-performance (COP) sourcing of services…
Navigating Tax Risk in the Modern Era: Why Tax Technology Is Essential In today’s ever-changing tax world, managing the organization’s tax risk…
Optimizing Your Tax and IT Stack Tax leaders, tax technologists, chief financial officers (CFOs), and chief…