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How To Bind Without Getting in One: Avoiding Controversy Over Signature Authority Issues
It’s late in the day. After weeks of review, it’s time to file an entity classification election for an entity in your company’s structure. The election is due today. You have already carefully analyzed the ramifications of the election. Form 8832 has been drafted, reviewed, and approved. All that is… Read more »
The Impact of Loving and Ridgely on Corporate Tax Practice
Former OPR Director Reflects on Her Tenure at the IRS
Many TEI members are acquainted with the IRS’s Office of Professional Responsibility (OPR) and Karen Hawkins, its director until just a few months ago. In the first day of her new life, Hawkins graciously agreed to talk to Tax Executive about her tenure at OPR and the impact of two… Read more »
Forging Forward — But How Fast and in Which Direction?
Data rules the tax technology roost, elevating professionals who embrace its potential, but the “new normal” is not without its pitfalls
In the world of real estate, it’s all about location, location, and location. In the tax world, it is becoming all about data, data, and data. And whatever facet of tax technology you’re talking about—whether it’s hardware, software, Big Data, the cloud, data storage, or cybersecurity—the data are the key drivers.… Read more »
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…
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…