Author: Lowell Yoder, David Noren, and Britt Haxton

The Sixth Circuit’s Whirlpool Opinion—What’s the Impact?
Ruling disregards regulatory manufacturing exception but preserves right to rely on regulations in applying branch rule

by Lowell Yoder, David Noren, and Britt Haxton
July 15, 2022
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The US Court of Appeals for the Sixth Circuit issued a majority opinion in Whirlpool Financial Corporation & Consolidated Subsidiaries v. Commissioner1 that disregards the regulatory manufacturing exception to foreign base company sales income (FBCSI). That said, taxpayers still have the right to rely on the regulations in applying the…

TEI’s Monthly CTO Discussion Group Series

by Tax Executive Staff
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TEI has launched a new monthly discussion series for members serving in the role of chief tax officer/head of tax, where we tackle timely topics of particular interest to those leading their company’s tax function. Over the past several months, these calls have addressed tax department hiring trends, insights on… Read more »

Tax Outlook 2022: The Halfway Mark

by Tax Executive Staff
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Earlier this year, BDO published the findings of its 2022 BDO Tax Outlook Survey, which aimed to gather data surrounding tax departments’ planning strategies, biggest concerns, and tax technology, among other topics. The good news is that the vast majority—seventy-two percent—of survey respondents said their tax departments were thriving, and… Read more »

TEI’s 2022 Federal Tax Course – Level 1

by Tax Executive Staff
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TEI’s perennially popular Federal Tax Course – Level 1 returned to its immersive in-person format at the Kellogg Hotel & Conference Center on the campus of Michigan State University in East Lansing, Michigan, last month. This year’s course—the first to be offered since April 2019—drew over ninety registrants from across… Read more »

TEI Tax Technology Seminar Proves Invaluable

by Tax Executive Staff
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Are You Current on Superfund Excise Taxes?

by Senay Redda
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If you’re a manufacturer or importer of chemicals and unfamiliar with Superfund excise taxes, which have recently been reinstated, this interview will give you peace of mind. It’s a discussion of the past, present, and future of Superfund excise taxes with Senay Redda, vice president of business development for indirect tax… Read more »

The Impact of Tax Credits and Incentives on Business Plans
The Expert: Matt Kelley

by Tax Executive Staff
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If you’re steeped in high-impact tax issues, you know how important tax credits and incentives can be when developing and implementing a business plan. They’re not only important—they also can be complex, especially in today’s economic climate. That’s why we thought a one-on-one interview with an expert would be valuable…

Demystifying the Settlement of California Tax Controversies
Perhaps the most unique—and surprising—aspect of the California administrative settlement process is the designated agency settlement bureau structure

by Tim Gustafson and Liz Cha
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California is a state of overflowing abundance. From technology to entertainment to produce, the state has it all and then some. So when it comes to tax agencies, why would California stop at one? Most states have a single department of revenue, finance, or taxation, but California has five tax…

Continuing Education Calendar

by Tax Executive Staff
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2022 Annual Meeting of the Members August 7–9 Newport Beach, CA US International Tax Course August 8–12 Atlanta, GA Audits & Appeals Seminar September 20–22 Tysons, VA 77th Annual Conference October 23–26 Scottsdale, AZ Mergers & Acquisitions Seminar November 14–15 Austin, TX 2023 73rd Midyear Conference March 19–22 Washington, DC… Read more »