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…
Michelle Schapiro
Los Angeles Chapter
Michelle Schapiro recounts her introduction to TEI more than twenty years ago. “From the time I started with The Cheesecake Factory, my former boss—and my current boss—were very involved with TEI and encouraged me to attend their seminars,” she says. “Since that time, I’ve been actively engaged with the local…
Continuing Education Calendar
2024 2024 Audits & Appeals Seminar September 10–12 Tysons, VA Federal Tax Course – Level 1 Simulive September 30–November 20 Virtual 79th Annual Conference October 27–30 San Antonio, TX TEI Webinar Series: Ethics CPE for Tax Professionals December 10–12 Virtual Tax Technology Webinar Essentials December 16–19 Virtual 2025 International… Read more »
Cleveland Chapter
Honors Larry Boron
On May 20, TEI’s Cleveland Chapter honored Larry Boron, who recently retired as head of tax at Sherwin-Williams. He has been a member of TEI since 1997 and served in numerous chapter roles, including chapter president and chair of the chapter’s International Tax Committee. Boron has been a staunch supporter…
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…
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…
Region 1
Holds Annual Canadian Tax Conference in Ottawa
TEI Region 1 held its fifty-sixth Annual Conference May 3–5 in Ottawa. Mark Caluori, Jun Ping, and Steve Saunders planned the conference, and incoming TEI International President Josie Scalia delivered opening remarks. The program included many notable speakers, including the Honorable Marc Noël, KC, partner at Osler, Hoskin & Harcourt…
Region 10
Annual Conference Takes Place in Dana Point
TEI Region 10 held its forty-fourth Annual Conference May 22–24 at the Waldorf Astoria Monarch Beach Resort & Club in Dana Point, California. The three days of educational sessions kicked off with a discussion of current tax policy, including the possibility of tax legislation on Capitol Hill, the OECD Pillars…
TEI Submits Comments on Stock Repurchase Excise Tax Proposed Regulations
On June 11, TEI submitted comments on the proposed regulations on the stock repurchase excise tax. TEI requested clarification on the method for electing to apply the proposed regulations retroactively to issuances and repurchases that occurred after December 31, 2022, but before the publication of the proposed regulations. TEI also… Read more »
TEI Regions 6 & 7
Hold IRS Liaison Meeting
On May 9, Regions 6 and 7 held their annual liaison meeting with the Internal Revenue Service in Chicago. Larry Pociask, Cathy Stevens, Angela Schlemmer, Sara Zelazny, Meredith Menden, and Ryan Gibbons moderated sessions with IRS speakers on LB&I compliance priorities, the research credit, the Taxpayer Advocate Service, transfer pricing,…
Are Tax Insurance Proceeds Taxable? Tax insurance has emerged as a cornerstone of corporate tax…
OBBBA Modifications to US Taxation of International Income The One Big Beautiful Bill Act (OBBBA), which was signed…
How Does Conformity Impact State Revenues After the OBBBA? State conformity with the Internal Revenue Code (IRC) refers to…
Are Research Credit Interviews and Write-Ups Obsolete? Upon joining a Big Four firm in Washington, D.C.—then known…
Janelle Gabbianelli According to Janelle Gabbianelli, her first job was the catalyst…
Why Co-Sourcing Tax Technology Is Your Best Bet In today’s complex regulatory landscape, tax departments are being pushed…