International
Transfer Pricing Operations and Compliance for In-House Tax Professionals
Even if you’re a smaller organization, don’t assume you won’t be audited or targeted
Transfer pricing has never been more important for in-house tax professionals to address, from compliance and analysis to overall tax planning. However, transfer pricing rules change rapidly and globally, largely as a result of the work of the Organisation for Economic Co-operation and Development (OECD) on the base erosion and… Read more »
How Remote Workforce Programs Trigger Myriad Tax Problems—Part Two
Analyzing taxable presence and nexus issues for employers
The coronavirus pandemic created an explosion in remote workforce programs, some temporary but others indefinite or permanent. Remote work situations can arise in a wide range of settings—some are planned, and others arise well after the fact as a surprise to the in-house tax team. One critical tax issue introduced… Read more »
GloBE Meets GILTI—Part Two
What’s the status of implementation?
Our article, “GloBE Meets GILTI,” which appeared in the January/February issue of Tax Executive, addressed how taxes on global intangible low-taxed income (GILTI) might be allocated. Sadly, the story was already out of date by publication. This follow-up article addresses not the possibilities, but rather what the Organisation for Economic… Read more »
GloBE Meets GILTI
What’s the status of implementation?
When the United States adopted the book minimum tax in July 2022 as part of the Inflation Reduction Act, it became clear that the country was not racing to implement Pillar Two issued by the Organisation for Economic Co-operation and Development in March 2022. But the enactment of the minimum… Read more »
TEI Roundtable No. 40: Foreign Tax Credit Regulations
Are you up-to-date?
For almost four decades, the foreign tax credit regulations have established a three-part net gain requirement for determining when a particular foreign levy is an income tax. Now, things have changed. We assembled a panel of knowledgeable tax practitioners in the space to discuss how these changes came about and… Read more »
Technical Corrections to the 2021 Final Foreign Tax Credit Regulations
Correcting the uncorrectable?
As readers are well aware, almost a year ago, on December 28, 2021, the Treasury Department issued final foreign tax credit regulations (hereafter the “final regulations”)1 finalizing the proposed regulations that Treasury had issued the prior year.2 On July 26, 2022, Treasury issued two sets of technical corrections to the… Read more »
TEI Roundtable No. 39: DEMPE Functions and Their Impact on International Taxes
What should we make of a concept encompassing the development, enhancement, maintenance, protection, and exploitation of IP?
At TEI’s 72nd Midyear Conference in Washington, D.C., the Institute conducted a terrific session that focused on the DEMPE functions—development, enhancement, maintenance, protection, and exploitation of intellectual property—as laid out by the Organisation for Economic Co-operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) Project and its impact on… Read more »
The Sixth Circuit’s Whirlpool Opinion—What’s the Impact?
Ruling disregards regulatory manufacturing exception but preserves right to rely on regulations in applying branch rule
The US Court of Appeals for the Sixth Circuit issued a majority opinion in Whirlpool Financial Corporation & Consolidated Subsidiaries v. Commissioner1 that disregards the regulatory manufacturing exception to foreign base company sales income (FBCSI). That said, taxpayers still have the right to rely on the regulations in applying the… Read more »
New Frontiers of Dispute Settlement in a Pillar One World—Part Two
The success of Pillar One largely depends on the effectiveness of dispute settlement disciplines
Part One of this article, which appeared in the March/April 2022 issue of Tax Executive, discussed the evolution of the international tax system leading up to the modern proposal to implement an OECD-championed multilateral tax treaty to bring order to an increasingly complicated and digitized world. The recent impetus to… 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 »
AI in the Tax Department: Getting Tax a Seat at the Table Artificial intelligence (AI) is reshaping business functions rapidly, yet many…
TEI Roundtable No. 51: The Future Corporate Tax Department As tax moves into the future, in-house professionals are experiencing…
The Impact of AI in R&D Tax Credits For the last several years we’ve heard that artificial intelligence…
Making Sense of CAMT Complexity The corporate alternative minimum tax (CAMT) under Section 55 of…
Question: What Are the Key Updates in the FASB Income Tax Disclosure Requirements? In 2023, the Financial Accounting Standards Board (FASB) issued Accounting Standards…
Breaking Down Real-Time Controls in Global Tax As governments implement digital approaches to tax filing, reporting, operations,…