Features

Who Is the Customer?
The ins and outs of market-based sourcing

Compared to the complexity of cost-of-performance (COP) sourcing of services for income tax purposes, a market-based approach to apportionment sounds downright simple. Instead of comparing the location of all payroll and material costs of generating revenue as in a COP calculation, for market-based sourcing one looks only to the location… Read more »

Prepare for Public Country-by-Country Reporting
Getting ahead of risks to reputation

With public country-by-country reporting (CbCR) on the horizon, companies with operations in Europe or Australia may soon have to disclose key information about their tax and business operations by jurisdiction. Companies with operations in Romania may be required to produce public CbCR filings as early as December 31, 2024 (for… Read more »

Q&A With Jim Bearden
Get a glimpse into the mind of a man built to lead—the right way

Jim Bearden is a former Marine officer and an expert on accountability in leadership—and he’ll be at TEI’s 79th Annual Conference this fall. There, Bearden will engage with attendees in a keynote address and a breakout session to help them develop better, culture-focused leadership habits. In lieu of the Roundtable… Read more »

The Rise of the Excise Tax
Final and proposed regulations for the excise tax on stock repurchases

In August 2022, Public Law No. 117-169—commonly called the Inflation Reduction Act of 2022—enacted Section 4501 of the Internal Revenue Code.1 The statute generally imposes a nondeductible one percent excise tax (the “excise tax”) on the net value of share repurchases by publicly traded domestic corporations in a given tax… Read more »

Key Challenges and Opportunities for Tax Directors in a Tightening Economy
Maximize tax savings but tread carefully with debt restructurings

Navigating a tightening economic cycle—characterized by prolonged high interest rates and uncertainty about future rate cuts—requires care and foresight. In the current financial climate, companies tend to accrue substantial net operating losses (NOLs), tax credits, and other tax assets and face deteriorating investments in their subsidiaries. Debt modifications and forbearances… Read more »

Meeting Pillar Two Calls for Tax Transformation and Single-Solution Efficiencies
Unified corporation-wide tax solutions permit tax strategizing rather than mere compliance and reactivity

A wait-and-see attitude characterizes this year’s global tax landscape, with the emergence of regulations like BEPS Pillar Two marking a pivotal moment. Designed to address base erosion and profit shifting, BEPS Pillar Two proposes a framework to establish a minimum global corporate tax rate. This initiative signifies a concerted effort… Read more »

TEI Roundtable No. 48: AI Implementation in Today’s Tax Landscape
A panel from TEI’s Tax Tech Seminar reconvenes to keep the conversation going on the evolution of artificial intelligence in tax

As artificial intelligence (AI) gains traction throughout the business world, tax is in the thick of it, aiming to take advantage of AI’s benefits while navigating the attendant complexities. At TEI’s Tax Technology Seminar held this spring in Orlando, one session spoke to those issues at length—an engaging conversation and… Read more »

Pillar Two and IRS Notice 2023-80
Offering clarity on QDMTTs and top-up taxes

Internal Revenue Service Notice 2023-80 (hereinafter “the notice”) provides the US government’s view on the foreign tax credit treatment of Pillar Two top-up taxes and makes a clear distinction between qualified domestic minimum top-up tax (QDMTT) and the extra-jurisdictional top-up taxes imposed by an income inclusion regime (IIR) and the… Read more »

State and Local Tax Implications for a Remote Workforce
As remote work becomes more common, withholding and nexus are among key considerations

State and local tax issues related to remote workforces have existed for many years. However, the pandemic—with the attendant drastic increase in employees working from home or elsewhere—has intensified these issues and brought them to the forefront of taxpayers’ attention. The remote work trend continues even as we emerge from… Read more »

Brief Overview of What the Pillar Two Directive Means for Multinational Companies
Pillar Two’s inconsistent adoption by EU member states could complicate an already intricate system of domestic and EU laws that businesses must navigate

Editor’s note: This article was written prior to the OECD’s new administrative guidance on Pillar Two, released June 17. This article examines two central points for multinational enterprises as they grapple with the complexities and novelties of Pillar Two. We first address nuanced interpretations of various points of guidance and… Read more »