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Searching for Shangri-La: Reflections on the OECD’s Digital Tax Project
Analysis begins and ends with discussion of twin pillars
The goal of rewriting international tax rules to adapt more fully to the digitizing economy has eluded policymakers over the past decade. Efforts to find an acceptable solution at the global level so far have failed to muster consensus as different constituencies have raised perceived shortcomings that have halted progress,… Read more »
Global Mobility During a Pandemic
Workforce issues take center stage
The COVID-19 pandemic has disrupted how US businesses operate, causing significant challenges as many seek to adapt to a harsh economic reality that has continued into 2021. As businesses navigate the crisis, they have managed a seismic shift in how American and global workforces operate that has disrupted and redefined… Read more »
The Pandemic’s Effect on Sales Tax Post-Wayfair
Expect even more uncertainty going forward
The COVID-19 pandemic has wrought disruption and change in practically every area in which we operate, and its effects on the sales tax environment are no different. What is particularly interesting about the operation of the sales tax is that states and businesses are still grappling with the groundbreaking developments… Read more »
A Major Development in Corporate Income Tax
What’s New Hampshire v. Massachusetts got to do with it?
The pandemic has caused drastic shifts in employment and business arrangements. Major tax implications have surfaced, and taxpayers have been eager for state guidance or federal legislation to address pandemic-related issues. But with limited state guidance, and with federal legislation completely stalled, one development has become the focus of our… Read more »
Top State Tax Policies You Can Expect to Deal With in 2021
Fiscal fallout from the pandemic takes hold
When states began their 2021 fiscal year budget processes in early 2020, just about every state anticipated revenue growth consistent with what it had seen in recent years. Most states had robust rainy-day funds, and some were looking at options to lower taxes. As we fast-forward to early 2021, few… Read more »
TEI Roundtable No. 33: Leveraging IT for State Tax Departments During the Pandemic
It’s difficult enough to manage state tax departments in “normal” times. But imagine if you had to do it in a pandemic. No imagination necessary anymore, of course. It’s as real as it gets, and we wanted to find out what this “new normal” has really been like, so, not… Read more »
TEI Roundtable No. 32: Working and Managing Tax Departments Remotely
Today, as a result of COVID-19, the words remote and virtual are omnipresent and ubiquitous. And, yes, those words are very familiar now to those who toil in the tax industry. As you know by now, TEI’s Annual Meeting this year was virtual, and, not surprisingly, one of the most… Read more »
To Rely On or Not to Rely On? Sub-Regulatory Tax Guidance in Turbulent Times
Sometimes criticism of IRS guidance seems justified, other times not so much
Taxpayers face an ever-increasing mélange of sub-regulatory guidance from the Internal Revenue Service and the Treasury Department.2 This guidance can take the form of proposed regulations, revenue rulings, notices, announcements, private letter rulings, and myriad other documents. Taxpayers in the middle of planning transactions, preparing returns, or tax controversies are… Read more »
NOL Carrybacks Under the CARES Act
Why it’s important to accelerate or otherwise maximize losses in 2020
Due to the disruptions and economic shutdowns caused by COVID-19, many corporate taxpayers will have net operating losses (NOLs) in 2020. The Coronavirus Aid, Relief, and Economic Security (CARES) Act offers these taxpayers the opportunity to turn 2020 NOLs into cash refunds. The CARES Act revived the NOL carryback that… Read more »
Understanding the Built-in Gain and Loss Rules of Section 382—and Possible Significant Changes on the Horizon
Unprecedented NOLs have accompanied unprecedented times
As we all welcome the new year, companies look forward to the future and hope to leave 2020 to the history books. Because of the lingering economic effects of COVID-19 and the expansion by the Tax Cuts and Jobs Act (TCJA) of the application of the Section 168(k) first-year bonus… Read more »


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