Features
Deploying Company Foundations in Battle for Tech Talent
Managing compliance issues, planning opportunities for tax departments are key concerns
With top companies in Silicon Valley and elsewhere engaged in heated competition to fill the increasing number of open job positions requiring technical skills, initiatives to expand the country’s pipeline of science, engineering, and technology talent is becoming a renewed priority for corporate philanthropy. Corporate tax departments have an important… Read more »
TEI Roundtable No. 8: Tax Talent in Transition
How to plan your next steps in the face of M&As, spinoffs, bankruptcies, outsourcing, and changing demographics
The days when a young tax professional at a corporation worked his or her way up the ladder and stayed with the same company for an entire career are falling by the wayside. True, those days are not disappearing entirely, but most tax professionals move among several different opportunities at… Read more »
TEI Roundtable No. 7: Engaging Emerging Tax Professionals
Tax Executives Institute has implemented several initiatives aimed at increasing participation among emerging tax professionals, including the formation of an Emerging Tax Professionals Subcommittee. Tax Executive convened a roundtable discussion, moderated by Senior Editor Michael Levin-Epstein, to find out what the subcommittee was doing and the ways emerging tax professionals… Read more »
The New LB&I
Recent IRS reorganization raises panoply of significant issues
For a large majority of business taxpayers and their in-house tax professionals worldwide, the Large Business & International Division (LB&I) of the Internal Revenue Service (IRS) represents the principal point of regular interface with the U.S. taxing agency. Thus, any changes, whether large or small, in scope, focus, or operation… Read more »
Altera Deconstructed: A Nuanced Alteration in Tax Law
Tax Court’s Unanimous Opinion Deals With Unusual Regulatory Situation
On July 27, the Tax Court issued a unanimous opinion1 in Altera Corporation v. Commissioner, 145 T.C. No. 3 (2015), in which the court held that Treas. Reg. § 1.482-7(d)(2) is invalid. It is relatively rare for a court to invalidate Treasury regulations, and, for that reason alone, the decision… Read more »
Are You Considering an Advance Pricing Agreement?
Companies Need To Conduct Benefit Analysis To Determine If APA Is Best Approach
In 1991 the Internal Revenue Service (IRS) established the Advance Pricing Agreement (APA) program, allowing a taxpayer to request that the IRS, and potentially other countries, prospectively approve its transfer pricing facts, transfer pricing methodology, and arm’s-length range of results. The certainty provided by this prospective approach, combined with the… Read more »
The OECD’s BEPS Final Report
Part I: Introduction and Background 15 Actions, Dozens of Questions Maybe the anticipation didn’t reach that of ardent fans waiting for the trailer to the next Star Wars movie. And maybe it didn’t rival that of passionate followers of Harry Potter breathlessly lining up at midnight to make sure they… Read more »
The Trials and Tribulations of the Family Office
Get ready to deal with the trappings of wealth and leveraging the next generation’s tax exemptions
If you’re a veteran family office adviser, you’ve spent decades working with the family’s estate-planning counsel to ensure that wealth is passed to succeeding generations as tax efficiently as possible. You faithfully oversee the implementation of annual exclusion gifts, intrafamily loans, and rolling grantor-retained annuity trust (GRAT) programs, and you… Read more »
Roundtable No. 6 The Evolving Role of the Chief Financial Officer
As Compliance, Reporting, and BEPS Become More Complicated, so Does the Role of the CFO
Channeling Kevin Bacon in the movie A Few Good Men, these are the facts, and they are indisputable: As the role of the chief tax officer (CTO) becomes geometrically more complex (see Roundtable No. 5, September/October 2015 issue of Tax Executive), so does that of the chief financial officer (CFO).… Read more »
How To Bind Without Getting in One: Avoiding Controversy Over Signature Authority Issues
It’s late in the day. After weeks of review, it’s time to file an entity classification election for an entity in your company’s structure. The election is due today. You have already carefully analyzed the ramifications of the election. Form 8832 has been drafted, reviewed, and approved. All that is… Read more »
Optimizing Your Tax and IT Stack Tax leaders, tax technologists, chief financial officers (CFOs), and chief…
TEI Roundtable No. 49: A Look at the TCJA in 2025 Editor’s note. This conversation was recorded in August, prior to…
Inequitable Barriers to Equitable Apportionment Every state that imposes a corporate income tax requires multistate…
Renewable Energy Tax Credits After the Inflation Reduction Act Following the the 2024 US general election, with Donald Trump’s…
Prepping for Year-End: Internal Control Over Financial Reporting As year-end approaches, tax departments can already sense the year-end…
In Memoriam: Tom Maletta TEI Past International President Tom Maletta passed away in November.…