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Excising Stock Buybacks From the Corporate Playbook
How will the excise tax be applied to taxpayers in light of the statutory language, Notice 2023-02, and Announcement 2023-18?
On August 16, 2022, the Inflation Reduction Act of 2022 (the IRA) was signed into law.1 Among a number of changes the IRA introduced to the Internal Revenue Code of 1986 was a new excise tax imposed on what are commonly referred to as stock buybacks by publicly traded corporations.… Read more »
TEI Roundtable No. 44: Leadership Development and Succession Planning
One critical factor is finding high-potential candidates on the team
As we’ve learned from the fabulous TV series Succession, leadership development and succession planning can often get a little, shall we say, dicey. Fortunately, in the tax realm, it doesn’t get quite as chaotic as in the Roy family. To find out more about best practices in our profession, we… Read more »
New Developments in Canada’s General Anti-Avoidance Rule
Is Canada overreaching with proposed changes?
Editor’s note. This article was written in early May. In Deans Knight Income Corporation v. The King, on May 26 the Supreme Court of Canada reached a seven-to-one decision in favor of the government. The past twelve months have seen two very significant developments in the general anti-avoidance rule (GAAR)… Read more »
Oops! I Did It Again: Practical Implications of Revenue Procedure 2022-39
Regardless of how errors occur, they must be dealt with
A fact, well known in the tax community: every tax return contains at least one error. Except for the simplest Form 1040, this statement is invariably true, especially considering the increasing complexity of corporate returns.1 First, what is meant by an “error” on a tax return? No definition exists in… Read more »
TEI Roundtable No. 43: Separate, Combined, and Worldwide Unitary State Filings
Some practical advice for making these key decisions
One of the most talked-about education sessions at this year’s Midyear Conference in March was the session titled “Separate, Combined, and Worldwide Unitary State Filings—What’s New?” We thought this very important state and local tax topic deserved more discussion, so we convened a roundtable in May to take a deeper… Read more »
Market Sourcing or Bust: The Kitchen Sink Approach of COP-Sourcing States
The binary nature of the determination makes COP sourcing controversial
The division of multistate business income among the states is accomplished through formulary apportionment. State formulary apportionment provisions increasingly rely on the receipts factor to divide income, sharpening the focus on the sourcing of receipts. Although many states have transitioned to a market-sourcing (also known as destination sourcing) approach, historically… Read more »
TEI Roundtable No. 42: A Deep Dive Into the Murky Waters of UTPs
Uncertain tax positions (UTPs) offer taxpayers both opportunities and challenges. We wanted to take a closer look at this important issue, so, of course, we assembled a roundtable of knowledgeable tax professionals, including George Clarke, partner at the Washington, D.C., office of Baker McKenzie; George Hani, member with Miller &… Read more »
How Remote Workforce Programs Trigger Myriad Tax Problems—Part Two
Analyzing taxable presence and nexus issues for employers
The coronavirus pandemic created an explosion in remote workforce programs, some temporary but others indefinite or permanent. Remote work situations can arise in a wide range of settings—some are planned, and others arise well after the fact as a surprise to the in-house tax team. One critical tax issue introduced… Read more »
GloBE Meets GILTI—Part Two
What’s the status of implementation?
Our article, “GloBE Meets GILTI,” which appeared in the January/February issue of Tax Executive, addressed how taxes on global intangible low-taxed income (GILTI) might be allocated. Sadly, the story was already out of date by publication. This follow-up article addresses not the possibilities, but rather what the Organisation for Economic… Read more »
TEI Diversity, Equity, & Inclusion Survey Results
Uncovering root challenges in recruiting and retaining talent
The many benefits of a diverse and inclusive workplace include increased revenue, improved employee engagement, and more innovation. Despite the great strides that have been made in driving awareness of the importance of diversity, equity, and inclusion (DEI) in the workplace, much work still needs to be done within the… Read more »
Tax Department of the Future: Reimagining Tax Technology On the first full day of TEI’s 75th Anniversary Celebration,…
State Tax Policy Takes Center Stage In an informative session on the first day of the…
The New Era of Transparency: Global Trends and Management Strategies In a particularly engaging session at TEI’s Annual Conference and…
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…
Global Tax Policy and Controversy Trends In an engaging and educational Annual Conference session moderated by…