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TEI Roundtable No. 28: The Landmark Tax Legislation’s Impact on International Tax
A 2020 perspective
It’s been a couple of tax cycles since the most comprehensive legislative revisions to the tax code in more than three decades were enacted. To take a look back, focus on the present, and take a quick look at the future concerning its impact on international tax issues, we convened… Read more »
Deftly Navigating an MTC Audit: Considerations for Taxpayers
Check out this stat: In the last three years, the MTC Audit Program has recommended state tax assessments in excess of $45 million annually
As recently recognized by Tax Analysts, the Multistate Tax Commission (MTC) has been gaining in prominence and, arguably, effectiveness.1 One of the MTC’s several activities is to administer audits on behalf of states. The MTC’s Joint Audit Program (Audit Program) is authorized by the Multistate Tax Compact and was initiated… Read more »
Life (and Litigation) After Wayfair
Did Wayfair establish South Dakota SB 106 as the new bright-line rule?
In the May/June 2018 edition of Tax Executive, TEI graciously published my article titled “Why Wayfair Won’t Matter.” Admittedly, the title was a bit deceiving, what millennials disparagingly refer to as “clickbait.” Contrary to the title’s suggestion, I did not argue that the palpable buzz around Wayfair was unwarranted. Instead,… Read more »
TEI Roundtable No. 27: State Tax Issues, 2019–2020
In general, taxpayers want more guidance
In the last few years, there’s been a discernable focus on federal tax issues in the wake of the passage of the most comprehensive tax reform package in three decades. But much of the action is taking place in state legislatures and state departments of taxation. We wanted to get… Read more »
Looking Ahead: Predictions on Upcoming State Tax Legislation
Key drivers are state economy and gubernatorial election cycle
With the turn of the new year and a new decade, it is only natural to try to predict what state tax legislation may become law in 2020. Many factors can affect the nature and pace of state tax legislation, but perhaps the two leading drivers are the state economy… Read more »
Don’t Throw Out New Jersey Throwout Cases
Why? It’s really a national issue
The New Jersey throwout wins are more nationally relevant than ever, even though New Jersey repealed the throwout provision in its Corporation Business Tax Act nearly a decade ago. “Throwout” takes its name from the requirement that receipts be removed from (or “thrown out” of) a company’s sales factor denominator… Read more »
Addressing Proposed Section 382 Regulations in Current M&A Transactions
These revisions will impact deal terms and valuation
In September 2019, the Internal Revenue Service (IRS) and the Treasury Department issued proposed Section 382 regulations that, when finalized, would significantly reduce the value of net operating losses (NOLs) following Section 382 ownership changes, including those that occur in connection with mergers and acquisitions.1 In particular, the proposed regulations… Read more »
Intersection of National Security With M&A: The Committee on Foreign Investment in the United States
Why does the United States have laws that regulate M&A activity from a national security perspective, and why are those laws now getting more attention?
Once a sleepy, shadowy backwater of the federal government, the Committee on Foreign Investment in the United States (CFIUS)—the U.S. government’s principal mechanism for screening foreign investment to assess and address its potential impact on U.S. national security—has hit the big time. In the last eighteen months, Congress passed sweeping… Read more »
A More Collaborative Tax Controversy Approach?
Strategies for Exam and Appeals
Tax executives are familiar with the scenario: Internal Revenue Service examiners are in the building and are beginning to issue information document requests (IDRs) on routine and sensitive issues. One typical taxpayer response is to go on the defensive. This approach includes not voluntarily identifying issues and transactions; responding to… Read more »
A Tax Executive’s Guide to Spin-offs: 10 Things You Won’t See in Section 355
Advise board and officers to be careful about certain negotiations or public statements during pendency of the spin
Behind the closed doors of a corporate boardroom somewhere in America, the directors of a publicly traded company are discussing the future of their business. For many years, the company has operated two major divisions that have gradually diverged over time. These divisions (having the remarkably original names Business A… Read more »
Optimizing Your Tax and IT Stack Tax leaders, tax technologists, chief financial officers (CFOs), and chief…
An Overview of the EU Public Country-by-Country Reporting Rules The European Union (EU) has long been at the forefront…
Optimizing Tax Through Structured Data Storage and Data Pipelines In today’s fast-paced digital business environment, tax departments are under…
Renewable Energy Tax Credits After the Inflation Reduction Act Following the the 2024 US general election, with Donald Trump’s…
TEI Roundtable No. 49: A Look at the TCJA in 2025 Editor’s note. This conversation was recorded in August, prior to…
Preparing Now for 2025 Tax Legislative Activity Editor's note: This article was finalized prior to President Donald…