Institute News

TEI Comments on Canadian DST

On September 8, TEI submitted comments on a revised draft of the Canadian Digital Services Tax (DST) to the Department of Finance Canada. The comments included requests that 1) Canada join with the other 138 countries collaborating on the OECD’s Inclusive Framework to support the extension of the multilateral negotiations… Read more »

TEI Submits Comments on Canada’s Proposed GAAR Penalty

On September 8, TEI submitted comments to the Canadian Department of Finance regarding the department’s proposed tax penalty for transactions held subject to Canada’s general anti-avoidance rule (GAAR). TEI’s comments focused on the need for the GAAR penalty to have a true due diligence defense to its imposition and include… Read more »

TEI Submits Comments on Canada’s Bare Trust Reporting

On September 27, TEI submitted comments to the Canada Revenue Agency regarding new rules for reporting “bare trust arrangements.” TEI’s comments focused on the compliance burden the new rules would impose on corporations and other businesses, which in most cases would be duplicative of other reporting requirements already imposed on… Read more »

TEI Files Comments on Canada’s Proposed Pillar Two Legislation

On September 29, TEI submitted comments to the Department of Finance Canada regarding its proposed legislation to implement Pillar Two of the Organisation for Economic Co-operation and Development’s project on the taxation of the digitization of the economy. Canada’s legislation, titled the Global Minimum Tax Act, encompasses most, but not… Read more »

TEI Files Comments on the GloBE Information Return

On October 6, TEI submitted comments to the Organisation for Economic Co-operation and Development (OECD) and the European Commission regarding the GloBE Information Return (GIR) under Pillar Two of the OECD’s two-pillar approach to the tax challenges arising from the digitization of the economy. TEI’s comments focused on the volume… Read more »

TEI Files Comments on Canada’s Excessive Interest and Financing Expenses Limitation Rules

On September 13, TEI submitted comments to the Department of Finance Canada regarding proposed legislation that would implement an excessive interest and financing expenses limitation (EIFEL). TEI’s comments addressed the proposed implementation date of the EIFEL rules, the need to except existing debt obligations from the rules for a period… Read more »

Pillar One—Amount B: TEI Comments to the OECD

On September 1, TEI submitted comments responding to the Organisation for Economic Co-operation and Development’s (OECD’s) public consultation document regarding Pillar One—Amount B. TEI recommended the OECD make Amount B an elective safe harbor for multinational enterprises, increase the scope of the definition of “distributor,” and enhance the mechanisms for… Read more »

TEI Comments on Canadian Draft RUTT Form

On June 7, TEI submitted comments to the Canada Revenue Agency (CRA) regarding the draft Reportable Uncertain Tax Treatment (RUTT) form. Taxpayers must use the RUTT form to report certain items depend-ing on how those items are treated on a taxpayer’s relevant financial statements. TEI’s comments focused on recommendations to… Read more »

TEI’s New Student Committee

We are pleased to announce that TEI’s board of directors has approved the addition of a Student Committee at the 2023 Annual Meeting of Members. This appointment recognizes the increasing importance of inspiring students to pursue careers in taxation and acknowledges the efforts of TEI’s student members to launch TEI’s… Read more »

TEI Holds Its Inaugural International Tax Student Case Competition

On August 19, TEI held its inaugural International Tax Student Case Competition in Montreal. Five teams of four students each from universities in North and South America competed to determine which team could devise the best solution to a set of international tax issues. The Case Competition was the brainchild… Read more »