Features

TEI at Three Score and Thirteen: Respected, Essential-and Evolving
As new leaders inevitably emerge, seasoned professionals say TEI critical to professional, personal growth

Over seventy years ago, a core group of corporate tax professionals met in New York City and created an organization to serve the professional needs of in-house tax executives. Meeting the education, networking, and advocacy needs of business tax professionals has anchored Tax Executives Institute ever since. Over the ensuing… Read more »

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TEI Roundtable No. 11: What Keeps CTOs Up at Night
Retroactivity issues and the Apple case may trigger some angst, but what often cause concern for CTOs on the firing line are business developments they don't know about

  For chief tax officers (CTOs), there are everyday worries, and then there are worries that keep them up at night—BEPS, changing compliance requirements, and increasing demands on their time, to name just a few. Tax Executive convened a roundtable to discuss in more detail the changing role of CTOs… Read more »

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Tax Developments in 2016
Part 2: International Tax. A Whole New World for Intangibles

  As the year comes to a close, we have a natural tendency to reflect on the past twelve months. This year has been exciting and challenging. Brexit. Summer Olympics. The U.S. presidential elections. This also has been an exciting and challenging year for international tax professionals deciphering recent guidance.… Read more »

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Tax Developments in 2016
Part 1: Federal Tax Developments Under Sections 385, 355, and 382; and new rules on partnership audits dominate landscape

  This article reviews and analyzes recent law changes and IRS guidance for federal income tax issues this past year. Section 385 Proposed Regulations — Impact on Related-Party Financing Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify… Read more »

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TEI Roundtable No. 10: Tax Plans of the Presidential Candidates
Shockingly (Haha), Clinton and Trump Proposals Differ Dramatically

This is not your typical presidential election season. So, as we prepare this issue of the magazine, tax issues are not on the front burner. Who knows what will happen during the debates or as the campaign heads inexorably toward Election Day? For this roundtable, we convened a group of… Read more »

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Corporate Integration: Chairman Hatch’s Straightforward Approach to Tax Reform
Want to have input on the proposal? There's no time like the present

There is consensus that business tax reform needs to occur, but disagreement over how best to achieve it. Earlier this year, Sen. Orrin Hatch (R-UT), chairman of the Senate Committee on Finance (Senate Finance), announced that he was developing a corporate integration proposal. Although Chairman Hatch has not yet issued… Read more »

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2016 State Tax Bellwethers — Some Cautionary Notes
Commerce is changing – and, not surprisingly, the state and local tax milieu is shifting as well – so taxpayers need to be on their toes

In 2016 several states have used a variety of tools in an attempt to manage challenges that plague all states. From contesting established United States Supreme Court precedents to making broad-sweeping statutory interpretations of state laws, the landscape of state and local tax is shifting to address the evolution of… Read more »

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House Blueprint for Tax Reform Pushes Consumption Taxes Onto Center Stage
Shifting away from 1986-style reform, the drama is definitely in the details

On June 24, with much fanfare, House Republicans laid out the framework of a new tax reform proposal, frequently called a “blueprint” for tax reform. To date, most of the focus of tax reform discussions and the major Congressional committee and Obama administration efforts on tax reform have involved so-called… Read more »

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TEI Roundtable No. 9: Technology Standards & the Tax Function
Hosting issues, cloud-based data aggregation, and cybersecurity protection — mixed in with corporate tax requirements — are among the key concerns.

As technology standards continue to change, so do their impact on the tax function and corporate tax professionals. Tax Executive convened a roundtable to discuss the burgeoning relationship among technology standards, tax requirements, and the changing dynamics of tax professionals. Kelly Necessary, senior director of tax at Time Warner Cable;… Read more »

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Proposed Related-Party Debt vs. Equity Regulations: Section 385 — Reactions and Practical Responses
The proposed rules ignore commercial realities, create a bias toward third-party borrowing and equity investments, and mandate significant reporting obligations — but what can taxpayers do?

The proposed regulations ignore the commercial realities of doing business in a global economy. They create a bias toward third-party borrowing and equity investments in lieu of intercompany debt. If finalized in their current form, the proposed regulations will force companies to choose inefficient mechanisms for financing their operations and… Read more »

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