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TEI Roundtable No. 12: The Evolving Education of Tax Professionals
Trying to meet corporate needs for more well-rounded students in changing times

The education of tax professionals has never been as important—or as complex. Tax laws and regulations are proliferating, the international tax scene is burgeoning, online education is on the rise, and, according to some observers, many students expect different educational experiences. In November, we convened a roundtable to explore these… Read more »

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Remembering Matthew, Ken, and Phil
Three Giants Who Changed the Practice of Tax

In the span of a few short months, the tax world lost three individuals—Matthew Rosen, Ken Gideon, and Phil Mann—who each left an indelible mark on tax law and tax practice. All three were affable, witty, and wise and possessed impeccably good judgment. They cared deeply about their families, friends,… Read more »

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TEI Roundtable No. 11: What Keeps CTOs Up at Night
Retroactivity issues and the Apple case may trigger some angst, but what often cause concern for CTOs on the firing line are business developments they don't know about

  For chief tax officers (CTOs), there are everyday worries, and then there are worries that keep them up at night—BEPS, changing compliance requirements, and increasing demands on their time, to name just a few. Tax Executive convened a roundtable to discuss in more detail the changing role of CTOs… Read more »

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Celebrating Milestone Chapter Anniversaries
From Five to Seventy Years Old, TEI Chapters Hit the Mark

  Individual TEI chapters are the lifeblood of the Tax Executives Institute. The chapters host educational meetings, including all-day CPE events and annual tax conferences; award graduate assistantships and scholarships; perform valuable community services; honor members with meritorious service awards; host luncheons; support TEI’s institute-level programs; host Congressional representatives; and… Read more »

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Tax Developments in 2016
Part 2: International Tax. A Whole New World for Intangibles

  As the year comes to a close, we have a natural tendency to reflect on the past twelve months. This year has been exciting and challenging. Brexit. Summer Olympics. The U.S. presidential elections. This also has been an exciting and challenging year for international tax professionals deciphering recent guidance.… Read more »

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Tax Developments in 2016
Part 1: Federal Tax Developments Under Sections 385, 355, and 382; and new rules on partnership audits dominate landscape

  This article reviews and analyzes recent law changes and IRS guidance for federal income tax issues this past year. Section 385 Proposed Regulations — Impact on Related-Party Financing Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify… Read more »

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Corporate Integration: Chairman Hatch’s Straightforward Approach to Tax Reform
Want to have input on the proposal? There's no time like the present

There is consensus that business tax reform needs to occur, but disagreement over how best to achieve it. Earlier this year, Sen. Orrin Hatch (R-UT), chairman of the Senate Committee on Finance (Senate Finance), announced that he was developing a corporate integration proposal. Although Chairman Hatch has not yet issued… Read more »

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TEI Roundtable No. 10: Tax Plans of the Presidential Candidates
Shockingly (Haha), Clinton and Trump Proposals Differ Dramatically

This is not your typical presidential election season. So, as we prepare this issue of the magazine, tax issues are not on the front burner. Who knows what will happen during the debates or as the campaign heads inexorably toward Election Day? For this roundtable, we convened a group of… Read more »

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2016 State Tax Bellwethers — Some Cautionary Notes
Commerce is changing – and, not surprisingly, the state and local tax milieu is shifting as well – so taxpayers need to be on their toes

In 2016 several states have used a variety of tools in an attempt to manage challenges that plague all states. From contesting established United States Supreme Court precedents to making broad-sweeping statutory interpretations of state laws, the landscape of state and local tax is shifting to address the evolution of… Read more »

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Proposed Related-Party Debt vs. Equity Regulations: Section 385 — Reactions and Practical Responses
The proposed rules ignore commercial realities, create a bias toward third-party borrowing and equity investments, and mandate significant reporting obligations — but what can taxpayers do?

The proposed regulations ignore the commercial realities of doing business in a global economy. They create a bias toward third-party borrowing and equity investments in lieu of intercompany debt. If finalized in their current form, the proposed regulations will force companies to choose inefficient mechanisms for financing their operations and… Read more »

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