Institute News
TEI Comments on IRS Notice 2023-7 Regarding the New Corporate AMT
On March 20, TEI submitted a letter to the Internal Revenue Service commenting on Notice 2023-7, which provides initial guidance on the new corporate alternative minimum tax (CAMT) imposed by the Inflation Reduction Act of 2022. TEI’s recommendations included the need for transition rules and penalty relief and adjustments to… Read more »
TEI Presents President’s Award to Michael Bernard
TEI also presented the President’s Award to Michael Bernard at TEI’s 73rd Midyear Conference. In his nomination of Bernard for the award, TEI’s international president, Wayne Monfries, detailed Bernard’s accomplishments as follows: In accordance with Tax Executives Institute’s award guidelines, I am pleased to nominate Michael (Mike) J. Bernard for… Read more »
TEI Files Amicus Brief in Maryland Digital Advertising Tax Litigation
On March 30, TEI filed an amicus brief in Comcast v. Maryland, which is pending before the Maryland Supreme Court. The fundamental substantive issue in this case is whether the Maryland Digital Advertising Tax (DAT)—which was enacted in 2019—is constitutional. Rather than focus on the substantive issue, the TEI brief focused… Read more »
TEI Presents President’s Award to David Stevens
TEI also presented the President’s Award to David Stevens at TEI’s 73rd Midyear Conference. In his nomination letter, TEI’s international president, Wayne Monfries, detailed Stevens’ accomplishments as follows: In accordance with Tax Executives Institute’s award guidelines, I am pleased to nominate David (Dave) Stevens to receive TEI’s President’s Award. Dave… Read more »
TEI Submits Comments Regarding Proposed Canadian 2% Buyback Tax
On February 23, TEI submitted comments to the Canadian finance minister, Chrystia Freeland, regarding the proposed Canadian 2% tax on share buybacks. TEI took the view that Canada should not implement a share buyback tax. Should Canada implement such a tax, however, the Institute’s recommendations included that the tax be… Read more »
TEI Posthumously Honors Eric Lee Johnson With the President’s Award
TEI posthumously honored Eric Lee Johnson with the President’s Award at TEI’s 73rd Midyear Conference. Kris Rogers, Johnson’s partner, accepted the award, which recognizes and expresses the Institute’s appreciation for long-term meritorious service. Johnson’s parents, Johnny and Sally, his sister, Monica, and nephew, Jonah, joined us in Washington, D.C., for… Read more »
TEI Submits Comments on Notice 2023-2 and the Stock Repurchase Excise Tax
On March 20, TEI submitted comments in response to a request for comments in Notice 2023-2, which provided guidance on the stock repurchase excise tax. The comments requested carve-outs from the tax for redemptions of nonparticipating, nonconvertible preferred stock and addressed the funding rule and related per se rule that… Read more »
In Memoriam: Eric Lee Johnson
1968–2023
The TEI community recently lost an amazing tax professional and TEI member, Eric Lee Johnson. For those of you who knew him and for those of you who didn’t, we wanted to let you about his accomplishments. Johnson was senior vice president of tax and legislative affairs for Ross Stores,… Read more »
TEI Comments on OECD Consultation on Pillar One, Amount B
On January 25, TEI submitted comments to the Organisation for Economic Co-operation and Development (OECD) regarding the OECD’s public consultation on the design elements of Pillar One, Amount B. TEI’s comments included the need to broaden the scope of Amount B to achieve its goal of transfer pricing simplification, ensure… Read more »
TEI Submits Comments on Proposed Changes to Schedule UTP
On November 17, TEI submitted comments to the Internal Revenue Service on proposed changes to Schedule UTP. The comments identified various critical policy issues that must be evaluated in a thoughtful and deliberative manner and urged the IRS to put an indefinite hold on the proposed changes and engage in… Read more »


Intangible Asset Valuation for Tax Purposes Under Fair Market Value and Arm’s-Length Standards Business transactions such as mergers, acquisitions, and business reorganizations often…
The New Corporate Alternative Minimum Tax: Five Not-So-Obvious Rule Applications to Consider Editor’s note: This article was written in mid-December 2022. It…
How Remote Workforce Programs Trigger Myriad Tax Problems—Part One Editor’s note: Given the complexity of this topic, this will…
Embracing ESG: Four Ways Tax Departments Can Add Value Environmental, social, and governance (ESG) considerations command a continually growing…
In Memoriam: Eric Lee Johnson The TEI community recently lost an amazing tax professional and…
How Remote Workforce Programs Trigger Myriad Tax Problems—Part Two The coronavirus pandemic created an explosion in remote workforce programs,…