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Canadian Tax Collection Provisions
The Expert: Blake Murray
A Canadian income tax assessment or GST/HST assessment triggers an immediate payment obligation and is subject to collection action by the Canada Revenue Agency (CRA), notwithstanding that the taxpayer is formally disputing the assessed amounts. It is important for taxpayers facing large Canadian tax assessments or negotiating indemnification provisions in respect… Read more »
IRS Interviews
The Experts: Jeffrey Friedman and Jessica Kerner
The Washington State Senate recently introduced a bill that would create an independent forum for hearing state tax appeals. This proposal follows the recent creation of the Alabama Tax Tribunal, the Illinois Independent Tax Tribunal, and the Georgia Tax Tribunal. These new tribunals represent significant changes that are improving the… Read more »
Intercompany Transactions: Current State Tax Developments
Nexus and documentation are key issues in understanding the current intercompany transaction legal landscape
Intercompany transactions can be used to shift income from entities with a physical nexus in many states to a related member with a limited nexus in favorable taxing jurisdictions. In moving to combat the benefits received from such intercompany transactions, states tend to employ one or more of the following… Read more »
LB&I Audits: Old Lessons, New Approach
Transparency, Collaboration, Fair and Efficient Resolution: No Argument with Goals, but the Devil Is in the Implementation Details
Those who ignore history are doomed to repeat it. That adage is true in all walks of life, but it is particularly appropriate as the IRS prepares to implement its most recent initiative for examinations by the Large Business & International division (LB&I), as described in the draft release of… Read more »
Optimizing Your Tax and IT Stack Tax leaders, tax technologists, chief financial officers (CFOs), and chief…
TEI Roundtable No. 49: A Look at the TCJA in 2025 Editor’s note. This conversation was recorded in August, prior to…
Renewable Energy Tax Credits After the Inflation Reduction Act Following the the 2024 US general election, with Donald Trump’s…
Inequitable Barriers to Equitable Apportionment Every state that imposes a corporate income tax requires multistate…
Prepping for Year-End: Internal Control Over Financial Reporting As year-end approaches, tax departments can already sense the year-end…
In Memoriam: Tom Maletta TEI Past International President Tom Maletta passed away in November.…