New Frontiers of Dispute Settlement in a Pillar One World—Part One
We’re witnessing an increased convergence of tax and trade in corporate risk management
Over the past several decades, the seemingly discrete disciplines of international tax and trade have become increasingly aligned as the globalization of corporate supply chains and the proliferation of online sales have accelerated. With this development, relations between the general counsel’s office and corporate tax departments have expanded. Corporate counsel…
TEI Comments on Proposed Interest Deductibility Limits in Canadian Budget 2021
On December 29, 2021, TEI submitted comments to the Department of Finance Canada concerning the government’s proposal to introduce a new limitation on the deduction of business interest expense, as described in Budget 2021. In general, the proposal would limit the amount of net interest expense that a corporation could deduct… Read more »
Calling all Partnership, Pass-Through, and Other Special Entity Members
TEI has launched a new discussion group in TEI Connect for members specializing in partnership, pass-through, and special entity taxation issues. Once established, the group will set calls to gauge interest in seminars, training, and other member needs. The discussion group will also be a resource to connect members seeking… Read more »
TEI Roundtable No. 37: Lessons Learned From TCJA Implementation
What are the implications for Biden’s proposals?
This roundtable was conducted on October 27 as the closing plenary session of TEI’s 76th Annual Conference in Florida. The session, Lessons Learned From TCJA Implementation and Implications for Biden’s Proposals, featured four distinguished panelists who shared their perspectives on the practical implementation and administration of business tax reform legislation:…
Government Aid Disclosure—Spotlight on the CARES Act
What accounting rules and guidance did companies follow to report receipt of government aid?
The United States has spent more government aid to combat the COVID-19 pandemic than at any other time in the country’s history. Due largely to pandemic spending, the United States federal government debt increased from $22.7 trillion to $28.5 trillion in the past two years, with much of the increased…
TEI Comments on Proposed Changes to Canada’s Income Tax Mandatory Disclosure Rules
On December 10, TEI submitted comments to the Department of Finance concerning the proposed changes to Canada’s income tax mandatory disclosure rules described in Budget 2021. TEI’s comments focus primarily on the government’s proposals to amend the Income Tax Act’s reportable transaction rules and introduce a new requirement for specified… Read more »
The Evolving Landscape of Cross-Border Tax Examination
Critical strategies for tax departments to consider and pitfalls to avoid in the complex landscape of foreign tax audits
Our clients and our practice group members are increasingly occupied (and preoccupied) not only with challenges from the Internal Revenue Service but also with audit and enforcement actions from foreign tax authorities. In a world where many jurisdictions are increasingly hungry for tax revenues, the foreign subsidiaries of large multinationals…
TEI Holds 2021 Virtual Liaison Meetings With Canada Revenue Agency and Department of Finance
On December 7–8, 2021, delegations of Canadian Income Tax Committee and Canadian Commodity Tax Committee members virtually participated in TEI’s annual liaison meetings with representatives of the Canada Revenue Agency (CRA) and Department of Finance. The 2021 meetings featured robust agendas covering a range of tax law, policy, and administration… Read more »
Chris Tressler
Detroit Chapter
An Overview of the EU Public Country-by-Country Reporting Rules The European Union (EU) has long been at the forefront…
Optimizing Tax Through Structured Data Storage and Data Pipelines In today’s fast-paced digital business environment, tax departments are under…
Preparing Now for 2025 Tax Legislative Activity Editor's note: This article was finalized prior to President Donald…
TEI Roundtable No. 51: The Future Corporate Tax Department As tax moves into the future, in-house professionals are experiencing…
How Tax Insurance Can Be a Valuable Tool for Managing Transfer Pricing Risk in 2025 and Beyond Heightened regulatory scrutiny around the world has made transfer pricing…
TEI to Comment on New Proposed Section 987 Regulations The US Treasury Department and Internal Revenue Service published new…