Institute News

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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TEI Submits Comments on the Capitalization of R&E Expenditures Under Section 174

On December 9, TEI submitted written comments to Congress regarding the changes to Section 174 under the Tax Cuts and Jobs Act of 2017. The comments urged Congress to act before the end of the 2022 calendar year to postpone, if not repeal, the mandatory capitalization of expenditures under Section… Read more »

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TEI Comments on OECD Pillar Two GloBE Information Return Consultation

On February 3, TEI submitted comments to the Organisation for Economic Co-operation and Development (OECD) regarding the GloBE Information Return under Pillar Two of the OECD’s project on the digitization of the economy. The Institute’s comments primarily focused on ways to reduce the volume of information required under the return,… Read more »

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Lynn Spence Promoted to Director, Information Technology & Web Services

TEI staff member Lynn Spence was promoted to director, information technology and web services in March. Spence joined TEI in February 2020 and has played an instrumental role with TEI through and after the pandemic, including moving TEI’s systems to the cloud, training staff and members on TEI resources, assisting… Read more »

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TEI Submits Comments on Draft Form RC312 Under Canada’s Mandatory Disclosure Rules

On February 13, TEI filed comments with the Canada Revenue Agency regarding Draft Form RC312 – Reportable Transaction and Notifiable Transaction Information Return. TEI’s comments primarily concerned the volume of information required by the form as well as the unclear nature of several provisions on the form. TEI’s comments were… Read more »

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TEI Submits Comments on Proposed Canadian EIFEL Rules

On January 31, TEI filed comments and recommendations with the Canadian Department of Finance regarding proposed excessive interest and financing expense limitation (EIFEL) legislation. The Institute’s recommendations included delaying the effective date of the rules, providing transition relief, and not applying the EIFEL rules when computing the foreign accrual property… Read more »

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TEI Requests Guidance on the Capitalization of R&E Expenditures Under Section 174

On November 30, TEI submitted written comments to the US Department of the Treasury and the Internal Revenue Service requesting guidance on changes to Section 174 under the Tax Cuts and Jobs Act of 2017, effective for tax years beginning after December 31, 2021. TEI’s comments were developed by members… Read more »

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TEI Comments on OECD Pillar Two GloBE Tax Certainty Consultation

On February 3, TEI provided comments to the Organisation for Economic Co-operation and Development (OECD) regarding its public consultation on GloBE tax certainty under the OECD’s two-pillar approach to the tax consequences of the digitization of the economy. The Institute’s comments focused on preventing and resolving tax disputes arising from… Read more »

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TEI Welcomes Three New Staff Members

We are excited to announce that three new staff members have joined TEI, bringing our total staff to sixteen full-time professionals. Judi Raigns Judi Raigns joined TEI in November as TEI’s new AMS administrator and data analyst. Raigns leads efforts to form data governance standards and serves as the central… Read more »

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