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TEI Roundtable No. 40: Foreign Tax Credit Regulations
Are you up-to-date?
For almost four decades, the foreign tax credit regulations have established a three-part net gain requirement for determining when a particular foreign levy is an income tax. Now, things have changed. We assembled a panel of knowledgeable tax practitioners in the space to discuss how these changes came about and… Read more »
The Presumption of Correctness
A pesky problem in state tax law
A common question tax directors ask when considering whether to litigate a state tax case is, What is the likelihood we will win? It’s an obvious question to ask, but an impossible one to answer. In our own experience, we have won cases we’d thought were stacked against us and… Read more »
Technical Corrections to the 2021 Final Foreign Tax Credit Regulations
Correcting the uncorrectable?
As readers are well aware, almost a year ago, on December 28, 2021, the Treasury Department issued final foreign tax credit regulations (hereafter the “final regulations”)1 finalizing the proposed regulations that Treasury had issued the prior year.2 On July 26, 2022, Treasury issued two sets of technical corrections to the… Read more »
Managing Corporate Foundation Risk
What role do in-house tax professionals play in advancing charitable objectives?
Causes worthy of support are plentiful, and new ones seem to appear daily. How a company responds to societal needs is more important than ever. More than 2,800 corporate foundations are estimated to exist in the United States.1 Many companies are moving away from traditional or responsive models of philanthropy… Read more »
Agents of Chaos: How Tax Leaders Are Adapting to Global Disruptions
Here are five ways tax groups can help senior leadership respond to uncertain times
This is not your parents’ inflation, but it will have wide-ranging implications for tax departments. Previous corporate playbooks for responding to external disruptions cannot begin to address the unique challenges posed by the current global economic decline following three consecutive shocks, ongoing trade wars, geopolitical unrest, and supply chain snarls.… Read more »
TEI Roundtable No. 39: DEMPE Functions and Their Impact on International Taxes
What should we make of a concept encompassing the development, enhancement, maintenance, protection, and exploitation of IP?
At TEI’s 72nd Midyear Conference in Washington, D.C., the Institute conducted a terrific session that focused on the DEMPE functions—development, enhancement, maintenance, protection, and exploitation of intellectual property—as laid out by the Organisation for Economic Co-operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) Project and its impact on… Read more »
Interview With IRS Deputy Chief Information Officer Kaschit Pandya
IRS and TEI working group coordinates efforts to optimize IRS technology
To keep current on tax issues, TEI members always like to hear directly from top Internal Revenue Service officials. So, we were thrilled when Kaschit Pandya, deputy chief information officer at the IRS, accepted our invitation to be interviewed by Brian Kaufman, vice president and tax counsel at Capital One… Read more »
Demystifying the Settlement of California Tax Controversies
Perhaps the most unique—and surprising—aspect of the California administrative settlement process is the designated agency settlement bureau structure
California is a state of overflowing abundance. From technology to entertainment to produce, the state has it all and then some. So when it comes to tax agencies, why would California stop at one? Most states have a single department of revenue, finance, or taxation, but California has five tax… Read more »
TEI Roundtable No. 38: The Tax Department of the Future
The more things change (and they definitely are changing), the more things will change some more
What does the tax department of the future look like? Not easy to predict, right? At the TEI Midyear Conference, we gathered a stellar panel to discuss crucial questions that impact every Institute member. Below is an edited transcript of half of that discussion, but not to worry. You… Read more »
You’ve Been Served: Defending Against a State Tax Class Action
Are you prepared for this rising threat to your business?
An email comes from the general counsel: your company has been sued by a customer who alleges that the company systematically overcharges sales tax.1 The complaint—the legal document that starts the lawsuit—contains multiple counts for various violations of state statutes and common law doctrines and demands damages, attorney’s fees, and… Read more »
Tax Department of the Future: Reimagining Tax Technology On the first full day of TEI’s 75th Anniversary Celebration,…
The New Era of Transparency: Global Trends and Management Strategies In a particularly engaging session at TEI’s Annual Conference and…
State Tax Policy Takes Center Stage In an informative session on the first day of the…
TEI’s 75th Anniversary Celebration: A Closer Look & An Optimistic Future This past October, we took the opportunity to recognize a…
TEI Bestows President’s Award on Makaris and Wireman, Honorary Membership on Silbiger Two of the highest honors a TEI member can receive…
The Market for Clean Energy Tax Credits Is Booming The Expert: Rob Parker Since Congress passed the Inflation Reduction…