Author: Sandhya Edupuganty

TEI’s 75th Anniversary Celebration: A Closer Look & An Optimistic Future

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This past October, we took the opportunity to recognize a significant milestone in TEI’s history—our 75th Anniversary Celebration—and we’re excited to dedicate this special issue of Tax Executive to share the occasion with all of our members. Those of you who joined us at the Annual Conference shared how special… Read more »

EMEA Chapter Members Report on OECD Stakeholder Meeting

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After more than seventy-five years, TEI’s global influence is, by any measure, enormous. An illustrative example is the recent Organisation for Economic Co-operation and Development (OECD) Stakeholder Day on Global Mobility, in which two members of TEI’s EMEA Chapter, Karine Halimi-Guez, vice president and head of tax at Booking.com, and… Read more »

Tax Credit Transferability and Direct Pay Proposed Under the IRA
Potential for interactions with Section 174 complicate a seemingly simple program

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The new tax credits in the Inflation Reduction Act (IRA) mean that more taxpayers will have access to more tax credits in the near future. But recent guidance highlights some uncertainties that taxpayers should be aware of before jumping in. The Treasury Department and the Internal Revenue Service recently released…

The Deference Doctrine—Its History and Possible Future
The Chevron doctrine has weathered changes since 1984, but the biggest one of all may be on the horizon

The doctrine of administrative deference, established in the Chevron case in 1984, requires deference to an agency’s reasonable interpretation of an ambiguous statute.1 The two-part test for requiring deference first addresses whether “Congress has directly spoken to the precise question at issue.”2 If so, the court must enforce the “unambiguous…

TEI Comments on Canadian DST

On September 8, TEI submitted comments on a revised draft of the Canadian Digital Services Tax (DST) to the Department of Finance Canada. The comments included requests that 1) Canada join with the other 138 countries collaborating on the OECD’s Inclusive Framework to support the extension of the multilateral negotiations… Read more »

TEI Roundtable No. 45: The 2023 Survey of Chief Tax Officers
Does your company have a tax technologist?

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Chief tax officers (CTOs) are integral to the fabric of TEI, with their own roundtable discussion group and their participation in all aspects of the organization. Recently, TEI held a CTO discussion group session regarding the role and prevalence of tax technologists and surveyed CTOs on several issues, including whether…

Josephine (Josie) Scalia

Josephine (Josie) Scalia developed an interest in tax in her first year at a Big Four accounting firm. Here’s her backstory: “I originally started my career in audit. When my husband and I decided to accept an opportunity to work in the US, I knew that we would need to… Read more »

Generative AI in Corporate Tax Departments

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A recent report by Thomson Reuters highlights the use of generative artificial intelligence (AI) tools in legal, corporate, and tax environments. Among findings in related fields, the report, titled “Future of Professionals: ChatGPT and Generative AI in Legal, Corporate & Tax Markets,” explores whether, in particular, corporate tax departments are… Read more »

Transfer Pricing Operations and Compliance for In-House Tax Professionals
Even if you’re a smaller organization, don’t assume you won’t be audited or targeted

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Transfer pricing has never been more important for in-house tax professionals to address, from compliance and analysis to overall tax planning. However, transfer pricing rules change rapidly and globally, largely as a result of the work of the Organisation for Economic Co-operation and Development (OECD) on the base erosion and…