Author: Timothy McCormally

In Memoriam: Charles W. Shewbridge III

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“Sometimes, everything comes together.” That tagline from a turn-of-the century Volkswagen commercial was how Charles W. Shewbridge III, TEI’s 1999–2000 international president, chose to open the annual report that summarized his year in office. Shewbridge, who died in Blowing Rock, North Carolina, on February 3, was a forty-year member of… Read more »

Are There Any Tax Incentives Left for the Energy Industry?
Let’s face it—multiple challenges confront the industry

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The US energy industry has faced many challenges in its history, from boom-and-bust oil prices to pressures from overseas oil producers to domestic government regulations. Today the industry continues to confront its share of challenges, including pressures to transition from fossil fuels to alternative renewable energy sources such as wind,…

Opportunity to Improve ADR Programs

The Government Accountability Office (GAO) is reviewing the alternative dispute resolution programs currently available in IRS Appeals and has asked TEI to assist in the process. TEI is assembling feedback regarding: experiences that led to satisfaction or dissatisfaction with ADR processes; views of why taxpayers might not be taking greater… Read more »

Tips From The Art of War to Help in Your Research Credit Battle
Some may consider the IRS a nemesis, but your battle may be gathering the necessary data and documentation to calculate and support the credit

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The legendary ancient Chinese general Sun Tzu has influenced Eastern and Western military thinking, coaching strategy, and now research tax credits.1 Some may consider the Internal Revenue Service a nemesis, but perhaps your own battle is to gather the necessary data or documentation to calculate and support the credit. To…

TEI Presents Awards

Deborah K. Gaffney TEI presented the Distinguished Service Award to Deborah K. Gaffney, TEI’s director of conference planning for thirty-five years until her retirement, at TEI’s Midyear Conference. The award recognizes outstanding service to TEI and the tax community. In his nomination of Gaffney for the award, TEI’s international president,… Read more »

Navigating the Automation Journey on a Budget 

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All tax departments either have begun or should be beginning the exciting and game-changing journey to automate their operations. But what does this really mean, from a practical budgetary perspective and from a mission-driven one? To find out, we interviewed two professionals in this arena, Mindy McGlaughlin, CPA and director… Read more »

Digital Transformation in the Tax World

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There’s no turning back when it comes to digital transformation in the tax space. But are you prepared to deal with it head on? To get a professional perspective, we turned to an expert who’s been navigating this digital sea change from its beginnings. Satnam Singh, chief product officer for… Read more »

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

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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…