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An Overview of the EU Public Country-by-Country Reporting Rules
A comprehensive breakdown, with guidance for preparation

The European Union (EU) has long been at the forefront of furthering corporate transparency and accountability. A significant step in this direction was the introduction of nonpublic country-by-country reporting (CbCR) rules in the EU for fiscal years beginning on or after January 1, 2016.1 The nonpublic CbCR rules require multinational… Read more »

TEI Roundtable No. 50: Compliance, Preparedness, and Risk After Loper Bright
How are tax departments evolving in its wake?

Following the Loper Bright decision, which effectively reduced the power of federal agencies to interpret ambiguous laws, tax departments are faced with potentially reevaluating compliance, litigation preparedness, and risk management strategies, among other issues. Recently, TEI convened a cadre of experts at its Audits & Appeals Seminar to speak on… Read more »

Preparing Now for 2025 Tax Legislative Activity
Looking ahead to the Trump administration and tax implications

Editor’s note: This article was finalized prior to President Donald Trump’s imposition of tariffs on Canada, Mexico, and China. January marked the beginning of the 119th Congress and President Donald Trump’s return to the White House. With full Republican control of the legislative and executive branches of government, Republicans are… Read more »

TEI Roundtable No. 49: A Look at the TCJA in 2025
With sunsetting provisions on the horizon, taxpayers hope for greater visibility

Editor’s note. This conversation was recorded in August, prior to the U.S. presidential election. Despite the election of Donald Trump in November, uncertainty remains surrounding the Tax Cuts and Jobs Act. No matter how the US election pans out in November, the new administration will have its hands full addressing… Read more »

Beyond the Numbers
Essential soft skills for leading corporate tax departments

What truly distinguishes exceptional tax leaders in today’s market? It’s not just their technical prowess—it’s their mastery of soft skills. This paradigm shift demands a new skillset for tax professionals. Today’s tax leaders are involved in everything from technical oversight, business strategy, C-suite discussions, and cross-functional collaboration to building a… Read more »

Renewable Energy Tax Credits After the Inflation Reduction Act
Successes, challenges, and the impact of the 2024 election

Following the the 2024 US general election, with Donald Trump’s victory, the future of the Inflation Reduction Act (IRA) enters a pivotal phase. Enacted in 2022, the IRA has been a cornerstone of the United States’ renewable energy strategy, offering tax incentives to drive investments in technologies like wind, solar,… Read more »

Inequitable Barriers to Equitable Apportionment
When petitioning for equitable apportionment, taxpayers face motley state-imposed obstacles

Every state that imposes a corporate income tax requires multistate businesses to apportion business income. The states’ methods of apportioning income, however, vary considerably and can produce inconsistent results. The United States Supreme Court sanctioned these differences in Moorman Mfg. Co. v. Bair1 when the Court allowed Iowa to deviate… Read more »

Who Is the Customer?
The ins and outs of market-based sourcing

Compared to the complexity of cost-of-performance (COP) sourcing of services for income tax purposes, a market-based approach to apportionment sounds downright simple. Instead of comparing the location of all payroll and material costs of generating revenue as in a COP calculation, for market-based sourcing one looks only to the location… Read more »

Prepare for Public Country-by-Country Reporting
Getting ahead of risks to reputation

With public country-by-country reporting (CbCR) on the horizon, companies with operations in Europe or Australia may soon have to disclose key information about their tax and business operations by jurisdiction. Companies with operations in Romania may be required to produce public CbCR filings as early as December 31, 2024 (for… Read more »

The Rise of the Excise Tax
Final and proposed regulations for the excise tax on stock repurchases

In August 2022, Public Law No. 117-169—commonly called the Inflation Reduction Act of 2022—enacted Section 4501 of the Internal Revenue Code.1 The statute generally imposes a nondeductible one percent excise tax (the “excise tax”) on the net value of share repurchases by publicly traded domestic corporations in a given tax… Read more »