Author: Kathy Pakenham and Adriana Wirtz

Planning for IRS Audits in an Era of Uncertainty
Using the economic substance doctrine as a general anti-abuse rule

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In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions.1 For example, last year, the IRS released Revenue Ruling 2024-14,2 establishing its position that the tax effect of certain related-party basis adjustment transactions should be disallowed under…

Jared Guidry
Dallas Chapter

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When you talk with Jared Guidry about tax, you immediately get the sense that you’re speaking with someone who loves what he does. After more than three decades in the field—and a decade leading the tax department at Exyte—it’s no surprise that his passion is matched by deep expertise. But…

Transfer Pricing and Valuation in Financial Transactions
The impact of OECD and IRS guidance on credit rating, debt capacity, and interest rates

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Business transactions such as mergers, acquisitions, and reorganizations often necessitate the pricing and valuation of financial transactions. Applying different standards may result in different pricing or valuation for the same financial transaction. Therefore, identifying the appropriate valuation standard is crucial. Companies must comply with ever-evolving financial and tax reporting requirements…

Preparing for Successful SALT Audits
Most of the work should occur long before the state tax notice arrives

Audit preparedness is crucial, since federal and state agencies have increased auditing to make up for budget deficiencies. In the complex, ever-evolving state and local tax (SALT) landscape, maintaining audit readiness and efficiently managing the audit process can be challenging for businesses, especially for entities operating in multiple tax jurisdictions.…

TEI Holds Seventh Annual Tax Technology Seminar

TEI welcomed more than 170 attendees, 137 speakers, and twenty-eight technology exhibitors to beautiful Renton, Washington, this past month for three full days of sessions, networking, and hands-on learning. This year’s seminar featured nearly forty sessions covering a wide array of tax technology topics, including artificial intelligence in tax, digital… Read more »

TEI Executive Director Elected as Fellow to American College of Tax Counsel

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On February 21, the American College of Tax Counsel (ACTC) board of regents elected TEI Executive Director Pilar Mata to be an ACTC fellow. ACTC membership is reserved for tax leaders who have made an exceptional contribution to their chosen profession, and the organization provides a venue for tax attorneys… Read more »

AI in the Tax Department: Getting Tax a Seat at the Table

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Artificial intelligence (AI) is reshaping business functions rapidly, yet many tax departments are still playing catch-up. Whereas marketing and sales teams often receive significant attention from organizations—with customer-driven analytics and automation—tax often remains an afterthought in broader AI discussions. It lacks the immediate, high-visibility impact of customer-facing applications, but its… Read more »