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Obtaining IRS Refunds: Procedures and Strategies
It’s rarely as simple as you think

Uncertainty in tax law is reaching unprecedented levels. In the past four years, taxpayers have managed dramatic tax reform, pandemic-fueled emergency tax legislation, rafts of new Treasury Regulations (and accompanying challenges to some regulations), and increased aggressiveness by certain tax authorities. Tax departments now must be nimbler than ever as… Read more »

New Frontiers of Dispute Settlement in a Pillar One World—Part One
We’re witnessing an increased convergence of tax and trade in corporate risk management

Over the past several decades, the seemingly discrete disciplines of international tax and trade have become increasingly aligned as the globalization of corporate supply chains and the proliferation of online sales have accelerated. With this development, relations between the general counsel’s office and corporate tax departments have expanded. Corporate counsel… Read more »

TEI Roundtable No. 37: Lessons Learned From TCJA Implementation
What are the implications for Biden’s proposals?

This roundtable was conducted on October 27 as the closing plenary session of TEI’s 76th Annual Conference in Florida. The session, Lessons Learned From TCJA Implementation and Implications for Biden’s Proposals, featured four distinguished panelists who shared their perspectives on the practical implementation and administration of business tax reform legislation:… Read more »

The Evolving Landscape of Cross-Border Tax Examination
Critical strategies for tax departments to consider and pitfalls to avoid in the complex landscape of foreign tax audits

Our clients and our practice group members are increasingly occupied (and preoccupied) not only with challenges from the Internal Revenue Service but also with audit and enforcement actions from foreign tax authorities. In a world where many jurisdictions are increasingly hungry for tax revenues, the foreign subsidiaries of large multinationals… Read more »

Why Unclaimed Property Risk Management Is on the Menu in 2022
For certain states, unclaimed property represents a significant revenue source

Every state has adopted an unclaimed property (or escheat) law, which generally provides that a holder of unclaimed property must escheat the property to the state after it has remained unclaimed by its owner for a certain period (usually three or five years). The unclaimed property is the legal obligation… Read more »

Protecting Privilege in ‘Work From Anywhere’ Era
The move toward remote or hybrid work arrangements is underway and irreversible

Even prior to the COVID-19 pandemic, tax functions were adapting and reacting to fundamental change and uncertainty. Whether the changes were brought about by the Tax Cuts and Jobs Act, by ever more aggressive positions taken by state and local auditors, by complex and burdensome reporting regimes, by novel taxes… Read more »

Presto Change-o: Unwinding Transactions in the Face of Uncertainty
It’s all about the rescission doctrine

With tax reform on the horizon, many companies are actively considering how the various proposals could impact their business and how they should structure their operations. However, many companies do not want to go all in and pull the trigger on a transaction based on what may amount to an… Read more »

The Changing Landscape of Indirect Tax
Guidance on emerging challenges in state and local indirect tax in the wake of COVID-19

The indirect tax landscape has changed rapidly in response to the COVID-19 pandemic. If the Supreme Court’s decision in South Dakota v. Wayfair in 2018 created a new playing field, complete with new marketplace facilitator guidance, the global pandemic has moved the goalposts. In this demanding environment, what is the… Read more »

Embracing the Certainty of Change
In challenging times, accept change and leverage opportunity

In a world where new laws and regulations seem to spring from nowhere, everything is subject to change. So, what should you do, TEI member? First, accept that uncertainty will be the norm with respect to domestic and international corporate tax policy. The congressional intent behind the laws that Treasury… Read more »

ESG Tax Transparency
You might want to check out BRT’s statement signed by 181 CEOs

In years gone by, business looked primarily to increasing shareholder returns, paying less attention to how their business practices affected the environment and society. For many, the primary concern in supply chain design was cost, with little inquiry into how supply chain partners conducted business. But more and more, such… Read more »

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