Author: Tax Executive Staff

TEI Files Comments on Canada’s Excessive Interest and Financing Expenses Limitation Rules

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On September 13, TEI submitted comments to the Department of Finance Canada regarding proposed legislation that would implement an excessive interest and financing expenses limitation (EIFEL). TEI’s comments addressed the proposed implementation date of the EIFEL rules, the need to except existing debt obligations from the rules for a period… Read more »

Pillar One—Amount B: TEI Comments to the OECD

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On September 1, TEI submitted comments responding to the Organisation for Economic Co-operation and Development’s (OECD’s) public consultation document regarding Pillar One—Amount B. TEI recommended the OECD make Amount B an elective safe harbor for multinational enterprises, increase the scope of the definition of “distributor,” and enhance the mechanisms for… Read more »

TEI Comments on IRS Notice 2023-7 Regarding the New Corporate AMT

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On March 20, TEI submitted a letter to the Internal Revenue Service commenting on Notice 2023-7, which provides initial guidance on the new corporate alternative minimum tax (CAMT) imposed by the Inflation Reduction Act of 2022. TEI’s recommendations included the need for transition rules and penalty relief and adjustments to… Read more »

TEI Presents President’s Award to Michael Bernard

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TEI also presented the President’s Award to Michael Bernard at TEI’s 73rd Midyear Conference. In his nomination of Bernard for the award, TEI’s international president, Wayne Monfries, detailed Bernard’s accomplishments as follows: In accordance with Tax Executives Institute’s award guidelines, I am pleased to nominate Michael (Mike) J. Bernard for… Read more »

TEI Files Amicus Brief in Maryland Digital Advertising Tax Litigation

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On March 30, TEI filed an amicus brief in Comcast v. Maryland, which is pending before the Maryland Supreme Court. The fundamental substantive issue in this case is whether the Maryland Digital Advertising Tax (DAT)—which was enacted in 2019—is constitutional. Rather than focus on the substantive issue, the TEI brief focused… Read more »

Market Sourcing or Bust: The Kitchen Sink Approach of COP-Sourcing States
The binary nature of the determination makes COP sourcing controversial

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The division of multistate business income among the states is accomplished through formulary apportionment. State formulary apportionment provisions increasingly rely on the receipts factor to divide income, sharpening the focus on the sourcing of receipts. Although many states have transitioned to a market-sourcing (also known as destination sourcing) approach, historically…

TEI Presents President’s Award to David Stevens

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TEI also presented the President’s Award to David Stevens at TEI’s 73rd Midyear Conference. In his nomination letter, TEI’s international president, Wayne Monfries, detailed Stevens’ accomplishments as follows: In accordance with Tax Executives Institute’s award guidelines, I am pleased to nominate David (Dave) Stevens to receive TEI’s President’s Award. Dave… Read more »

Let’s Take Notice of a Palpable Energy Surge

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As we enter the home stretch of my presidential year, I want to take note of the palpable surge of energy that has resulted from the return of TEI’s in-person events this year. Really, it’s been great to see all your faces and even better to watch the renewal of… Read more »