Features
Planning for People Within Your Technology Road Map
What path are you taking?
A road map lays out the path to get from where you are today to where you want to be in the future. In technology settings, the term is often used to conceptualize the work that needs to be completed for a technology solution to be ready for use. However,… Read more »
TEI Roundtable No. 36: The Total Transformation of the Tax Function
Technology—ERP, AI, robotics, and much, much more—is leading the way
Clearly, the corporate tax function has been transforming dramatically in the last decade as new technology has emerged at an accelerated pace. But we’ve been so busy keeping up with the evolving transformation, do we know exactly how it’s actually been changed? To get a handle on that thorny issue,… Read more »
Who Is Interested in My Request for Interest?
Procedural missteps can risk taxpayers’ pursuit of overpayment interest from the IRS
The law is clear: “If a taxpayer overpays its taxes, the IRS owes the taxpayer interest on that amount.”1 This obligation certainly characterized the Internal Revenue Service’s 2020 fiscal year, in which the IRS paid more than $3 billion of overpayment interest to taxpayers.2 This figure is just the latest… Read more »
Let’s Make a Federal Case Out of It: Time to Revisit the Tax Injunction Act
There’s been no change in the TIA in more than 80 years—really
Most state taxpayers would prefer to litigate state and local tax cases in federal courts. However, disputes over state and local taxes are almost always decided by state courts. Although litigation in state court may seem natural and obvious to most state tax professionals, it is somewhat odd given the… Read more »
The Global Tax Information Age
International exchange of info growing—but still room for development
For years, governments around the world have called for changes to tax administration to prevent abusive tax avoidance and tax evasion. The need for change has been driven in part by the increasingly globalized economy, where cross-border activities and transactions are the norm rather than the exception. The Organisation for… Read more »
Tales From the California Tax Controversy Trenches: Navigating FTB Sales Factor Audits
Proper planning can lead to a successful audit— or at least a more tolerable one
One of the California Franchise Tax Board’s1 guiding principles is to “administer the Revenue and Taxation Code . . . and be vigorous in requiring compliance with the law.”2 Our decades-long experience with California tax controversy provides perspective on the FTB’s vigor for compliance. This vigor is never more apparent… Read more »
TEI Roundtable No. 35: Enforcement in 2021—and Beyond
What can taxpayers realistically expect?
There’s a new sheriff in D.C., but what does that mean for taxpayers in terms of enforcement? That’s a difficult question. As you might expect, we convened a roundtable of some of the most notable forecasters in the tax space to discuss this issue, including Brad Pees, lead tax controversy… Read more »
Tax Rate Modeling in the New World of US International Tax
Foreign branch versus CFC and the GILTI high-tax exclusion are two essential modeling imperatives
The world is getting smaller and more complex. National economies are more integrated globally, but national deficits and the need for tax revenues are driving unilateral measures. The original objective of the base erosion and profit shifting (BEPS) project has been described as ensuring that profits are taxed where economic… Read more »
Searching for Shangri-La: Reflections on the OECD’s Digital Tax Project
Analysis begins and ends with discussion of twin pillars
The goal of rewriting international tax rules to adapt more fully to the digitizing economy has eluded policymakers over the past decade. Efforts to find an acceptable solution at the global level so far have failed to muster consensus as different constituencies have raised perceived shortcomings that have halted progress,… Read more »
TEI Roundtable No. 34: International Tax Issues and the Global Pandemic
No area of tax has escaped the influence of the global pandemic, and that certainly includes international tax, the theme of this issue of Tax Executive. But what exactly has the impact of COVID-19 been, and what is likely to be its impact throughout 2021? To take a deeper dive… 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,…