TEI’s committees have been engaged in numerous advocacy initiatives over the past several months. To learn more about TEI advocacy or join a committee, contact any member of the legal team.
TEI Files Comments on Foreign Tax Redeterminations Under Section 905(c)
On March 31, TEI submitted comments to the Internal Revenue Service regarding foreign tax redeterminations (FTRs) under Section 905(c). The post-Tax Cuts and Jobs Act final regulations resulted in a significant increase in the compliance burden on taxpayers with FTRs. TEI’s letter recommended several methods to reduce this compliance burden as well as the administrative burden on the IRS when auditing FTRs.
TEI’s comments were prepared under the aegis of its US International Tax Committee, whose chair is Ag Samoc. Benjamin R. Shreck, TEI tax counsel, coordinated the preparation of TEI’s comments. Read the comments here.
TEI Files Comments With the United Nations on the International Tax Cooperation Framework
On March 15, TEI submitted comments to the United Nations regarding its Terms of Reference for a United Nations Framework Convention on International Tax Cooperation. TEI’s comments focused on the need for clear and principle-based international tax rules, avoiding double taxation, and delineation of how international tax rules interact with local rules in each jurisdiction, among other things.
TEI’s letter was prepared under the aegis of its EMEA Direct Tax Committee. Benjamin R. Shreck, TEI tax counsel, coordinated the preparation of TEI’s comments. Read the comments here.
TEI Files Comments on the Revised Australian Public CbC Reporting Exposure Draft
On March 5, TEI filed comments with the Australian Treasury regarding the Australian government’s revised Exposure Draft proposing to require certain multinational corporations with operations in Australia to make public country-by-country (CbC) reporting information. TEI’s comments addressed the inconsistency of the data Australia would require to be published with other CbC data, the need for flexibility in how companies prepare the data to be published, and the need to protect competitively sensitive data, among other things.
TEI’s comments were prepared under the aegis of its Asia and EMEA Direct Tax Committees. Benjamin R. Shreck, TEI tax counsel, coordinated the preparation of TEI’s comments. Read the comments here.
TEI Files Comments on Australia’s Software Royalty Characterization Ruling
On March 1, TEI filed comments with the Australian Taxation Office regarding its new interpretation of the characterization of payments made for software and other intellectual property. TEI commented on how this new interpretation was out of step with longstanding and internationally accepted tax rules, that the new interpretation was likely to lead to increases in tax disputes and incidences of double taxation, among other things.
TEI’s comments were developed under the aegis of its EMEA Direct and Asia Tax Committees. Benjamin R. Shreck, TEI tax counsel, coordinated the development of TEI’s comments. Read the comments here.
