News
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 »
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 »
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 »
State and Local Tax Implications for a Remote Workforce State and local tax issues related to remote workforces have…
Tax’s Role in Tech Transformation As tax experiences its own transformation with technology, companies are…
Key Challenges and Opportunities for Tax Directors in a Tightening Economy Navigating a tightening economic cycle—characterized by prolonged high interest rates…
Question: How Can Companies Take Advantage of Digital Assets With No Tax Impact? Digital-asset-based loyalty and reward programs allow companies to create a…
The Rise of the Excise Tax In August 2022, Public Law No. 117-169—commonly called the Inflation…
TEI Roundtable No. 48: AI Implementation in Today’s Tax Landscape As artificial intelligence (AI) gains traction throughout the business world,…