Institute News

TEI Comments on Proposed Penalty for Canadian GAAR Violations

On May 31, TEI filed comments with the Department of Finance Canada regarding a proposal to impose a penalty on taxpayers who violate Canada’s general anti-avoidance rule (GAAR). TEI commented that a distinct penalty for violations of the GAAR was not necessary given the current structure of the Canadian income… Read more »

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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 »

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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 »

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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 »

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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 »

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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 »

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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 »

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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 »

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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 »

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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 »

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