New Frontiers of Dispute Settlement in a Pillar One World—Part Two
The success of Pillar One largely depends on the effectiveness of dispute settlement disciplines
Part One of this article, which appeared in the March/April 2022 issue of Tax Executive, discussed the evolution of the international tax system leading up to the modern proposal to implement an OECD-championed multilateral tax treaty to bring order to an increasingly complicated and digitized world. The recent impetus to…
Much Ado, but Little New: A Guide to Section 951(a) After Build Back Better
What are the ramifications of Congress’ proposal?
The definition of “pro rata share” in Section 951(a)(2) is fundamental to the subpart F regime. That regime, of course, dates to the John F. Kennedy administration.1 Most words in current Section 951(a)(2) do, too. Though Congress amended Section 951(a)(1) on numerous occasions, it has left undisturbed the words of…
TEI’s Monthly CTO Discussion Group Series
TEI has launched a new monthly discussion series for members serving in the role of chief tax officer/head of tax (CTOs), 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… Read more »
Todd Lard Joins TEI Staff
This past January, Todd A. Lard joined the TEI staff as tax counsel in Washington, D.C. He will support the advocacy and educational activities of TEI’s State and Local Tax Committee, whose priorities include legislative, administrative, and judicial advocacy involving complex state and local tax issues affecting businesses. Lard will… Read more »
Disrupting the Norm: Using Technology to Reinvent State Tax Compliance
It’s time to free up capacity and deal with remote work
In the current business environment, the only constant in the face of major economic and societal shifts is dynamic change. As companies forge ahead, their tax departments increasingly lead the way in sustainably transforming their business models and their digital and strategic footprints. Tax leaders are remaking their technology infrastructures…
Bloomberg: D&I in the Workplace
Diversity and inclusion (D&I) is one of the leading initiatives recognized by corporate tax and accounting firms and professionals, spurring several firms to conduct studies on the issue over the past few years. Bloomberg Tax’s recent report, Diversity and Inclusion Study: The Struggle to Meet D&I Goals, includes data from… Read more »
TEI’s Corporate Tax Department Survey: A Few Key Stats
In 2021, TEI launched a comprehensive Corporate Tax Department survey that highlights tax department makeup, budgeting, responsibilities, technology, and more. This survey is meant to enable tax professionals to more effectively benchmark those issues moving forward. TEI conducted similar surveys in 2004–2005 and 2011–2012, and the latest report includes insights… Read more »
Walter Doggett
A great teacher can often make an epic difference in your life. Just ask Walter Doggett, the executive tax director of E*Trade Financial Corporation and incoming TEI international secretary. While attending the University of Virginia, Doggett took elective tax courses from David LaRue, an experience that greatly influenced his future… Read more »
TEI Weighs In on the Build Back Better Act’s Corporate and International Tax Reform Proposals
Welcome to the latest installment of Advocacy Agenda, a periodic column in which I share select insights and observations of interest to TEI members about the tax policy advocacy environment in Washington, D.C. My last column, in the July/August 2021 issue of Tax Executive, attempted to set the scene for… Read more »
Celebrating Our Early 2022 Successes
We’re just a few months into 2022, but already we’ve had some terrific successes I want to tell you about. Midyear Conference First, as you read this, we’re on the verge of holding our second major hybrid event, TEI’s 72nd Midyear Conference, themed Tax Reform Redux—Seizing Opportunities and Mitigating Risks.… Read more »
AI in the Tax Department: Getting Tax a Seat at the Table Artificial intelligence (AI) is reshaping business functions rapidly, yet many…
Planning for IRS Audits in an Era of Uncertainty In its ongoing crusade against so-called “basis-shifting” transactions, the Internal…
Transfer Pricing and Valuation in Financial Transactions Business transactions such as mergers, acquisitions, and reorganizations often necessitate…
TEI Roundtable No. 53: Using AI for Tax Law Research As artificial intelligence continues its scorching rise, in-house tax professionals…
Andreia Verissimo Andreia Verissimo, the senior manager for US tax policy at…
TEI Roundtable No. 52: FASB Accounting Standards Update 2023-09—Income Taxes (Topic 740) As financial reporting evolves, the Financial Accounting Standards Board (FASB)…