News
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 »
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 »
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 »
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 »
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 »
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 »
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 »
An Overview of the EU Public Country-by-Country Reporting Rules The European Union (EU) has long been at the forefront…
Optimizing Tax Through Structured Data Storage and Data Pipelines In today’s fast-paced digital business environment, tax departments are under…
Preparing Now for 2025 Tax Legislative Activity Editor's note: This article was finalized prior to President Donald…
TEI to Comment on New Proposed Section 987 Regulations The US Treasury Department and Internal Revenue Service published new…
How Tax Insurance Can Be a Valuable Tool for Managing Transfer Pricing Risk in 2025 and Beyond Heightened regulatory scrutiny around the world has made transfer pricing…
TEI Welcomes New Staff, Promotes Team Member Erica Larkin Erica Larkin joined TEI in November as the…