Considerations in Tax Refund Litigation
Is refund litigation the path to releasing “stuck” refunds?
The Internal Revenue Service has seen unprecedented changes this year. Approximately 25,000 IRS employees—or twenty-five percent of its workforce—have accepted the deferred resignation or retired or were laid off.1 When we wrote this article in November, the federal government had been shut down for more than four weeks with only…
How Is Tax Policy Shaping the Future of Clean Energy Investment?
The Expert: Tom Bitting
US electricity demand is accelerating at a pace few anticipated. Growth in artificial intelligence (AI), electric vehicles, reshored manufacturing, and the large data centers that provide the connectivity infrastructure for each is pushing the power grid toward record new demand beyond its current capacity. Energy consulting firms predict sharp growth…
Calendar of Events
2026 US International Tax Course (Simulive Edition) January 21–March 11 Virtual Mergers & Acquisitions Seminar February 12–13 Houston, TX 76th Midyear Conference March 15–18 Washington, DC SALT Essentials Course (Simulive Edition) March 24–May 21 Virtual Tax Technology Seminar April 27–29 Las Vegas, NV Federal Tax Course – Level 1 April… Read more »
TEI Submits Comments on Notice 2025-44
On October 20, TEI submitted comments on Notice 2025-44, which announced the forthcoming withdrawal of final regulations concerning disregarded payments losses and related changes to the dual consolidated loss (DCL) rules, among other things. The letter included comments on the definition of foreign use, the DCL rules’ treatment of disregarded… Read more »
How the IRS May Do More With Less
As the IRS modernizes with AI and other tech, it faces funding cuts and shifting enforcement priorities
Facing ongoing budget constraints and a significant reduction in workforce, the Internal Revenue Service is changing its approach to taxpayer service, enforcement, and collections. Taxpayers and tax practitioners are seeing early signs of how the IRS is leveraging technology and data analytics as well as returning to some old practices…
TEI Comments on OBBBA Implementation
On November 10, TEI submitted comments on the implementation of a number of the provisions in the One Big Beautiful Bill Act (OBBBA). The comments focused on the interaction between the corporate alternative minimum tax (CAMT) and Section 174A, including a detailed discussion of the statutory grant of rulemaking authority… Read more »
The Unconstitutionality of the Brazilian QDMTT
New tax on multinational groups raises legal and equity concerns
On December 30, 2024, the government of Brazil published Law 15,079, which went into effect on January 1, 2025. It instituted the Additional Social Contribution on Net Income (Adicional da Contribuição Social sobre o Lucro Líquido, or ACSLL), a tax that applies to multinational entities operating in Brazil. The ACSLL…
Sales Tax Traps for Disregarded Entities
A handful of states pose hidden compliance risks
Sales tax rules can be confusing, because states often take different approaches to the same tax concept. In most cases, sales tax obligations apply at the level of each separate legal entity—even if that entity is disregarded for federal or state income tax purposes. Although this rule generally applies in…
On the TEI Strategic Plan
One of my primary goals as TEI’s international president has been to establish a clear, long-term strategic plan for the Institute. This effort began with a comprehensive member survey designed to gather candid feedback and insights from across our membership. In addition, we engaged McKinley Advisors to guide us through… Read more »
TEI Welcomes New IT Specialist
Tyler Davison joined TEI in January as IT support specialist. In his role, Davison will support web service and IT operations for the Institute. Before joining TEI, Davison worked with federal agencies supporting workflow automation, technical troubleshooting, and IT service management. He holds a bachelor’s degree in business administration (leadership… Read more »
Overreliance on AI for Tax Advice: A Cautionary Perspective With the increasing popularity of artificial intelligence (AI), many people…
Sales Tax Traps for Disregarded Entities Sales tax rules can be confusing, because states often take…
How Is Tax Policy Shaping the Future of Clean Energy Investment? US electricity demand is accelerating at a pace few anticipated.…
TEI Tax Technology Seminar Set to Deliver Once Again Each year, TEI’s Tax Technology Seminar brings together in-house tax…
Considerations in Tax Refund Litigation The Internal Revenue Service has seen unprecedented changes this year.…
The Unconstitutionality of the Brazilian QDMTT On December 30, 2024, the government of Brazil published Law…