Inequitable Barriers to Equitable Apportionment
When petitioning for equitable apportionment, taxpayers face motley state-imposed obstacles
Every state that imposes a corporate income tax requires multistate businesses to apportion business income. The states’ methods of apportioning income, however, vary considerably and can produce inconsistent results. The United States Supreme Court sanctioned these differences in Moorman Mfg. Co. v. Bair1 when the Court allowed Iowa to deviate…
TEI Submits Supplemental Comments on Notice 2023-63, Section 174, and Software Development
On October 2, TEI submitted supplemental comments on Notice 2023-63 and Section 174, with a particular focus on rules related to software development for future proposed regulations. The comments address timing issues with respect to specified research and development expenditures on wages, the appropriate nexus for indirect costs to be… Read more »
Thank You and Congratulations to TEI’s Committee Chairs
TEI could not accomplish its work without its technical and advisory committees. These committees develop TEI’s positions on tax matters, plan the Institute’s education programs, and interact with tax officials at every level. We would like to thank our 2023–2024 committee chairs for the work they have done for the… Read more »
TEI Submits Comments on GloBE Information Return XML Schema
On August 19, TEI submitted comments regarding the Organisation for Economic Co-operation and Development’s Draft User Guide for the Global Anti-Base Erosion Model Information Return XML Schema. TEI’s comments emphasized the need for information return exchange agreements, a uniform XML schema and filing portal, and a secondary filing mechanism, among… Read more »
Appointment of the 2024–2025 Executive Committee
Each year, the incoming international president selects an Executive Committee from the members of TEI’s board of directors to join the Institute’s four officers in their oversight of the Institute’s business affairs. We are excited to announce the following appointments for the 2024–2025 fiscal year:
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…
OECD Report Highlights Corporate Tax Rate Stabilization
According to a recent report and accompanying press release from the Organisation for Economic Co-operation and Development (OECD), statutory corporate tax rates are stabilizing across the globe following a steady period of declining rates. In the OECD’s 2024 edition of Corporate Tax Statistics released in mid-July, average statutory corporate tax… Read more »
TEI Submits Comments on EU Public CbCR Regulation
On August 28, TEI submitted comments regarding the European Commission’s draft implementing regulation for the commission’s public country-by-country (CbC) reporting directive. TEI’s comments focused on the need to clarify the scope and purpose of the information included in the public CbC reports for consistency across European Union member states in… Read more »
Comparing Tax Platforms Ahead of the 2024 US Presidential Election
Whereas the Republican candidate proposes to extend or make permanent much of the Tax Cuts and Jobs Act (TCJA) provisions, the Democrats would allow much of the TCJA provisions to expire as planned, resulting in higher taxes for some taxpayers and tax cuts for others. The Democrats plan to raise… 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…
Managing Canadian Tax Risk The global tax environment has seen fundamental changes in recent…
Transfer Pricing in Transition Although states experienced significant tax revenue growth during the COVID-19…
The One Big Beautiful Bill Act In July 4, President Donald Trump signed into law the…
Automation in Action: Key Takeaways From the TEI Automation Competition In February, tax professionals from across the country gathered in…
Beyond Automation: Why Having a Human in the Loop Is Critical for Sales Tax Compliance The allure of sales tax automation is undeniable. Many companies,…
TEI Holds Third International Tax Student Case Competition TEI held its third International Tax Student Case Competition at…