TEI Roundtable No. 40: Foreign Tax Credit Regulations
Are you up-to-date?
For almost four decades, the foreign tax credit regulations have established a three-part net gain requirement for determining when a particular foreign levy is an income tax. Now, things have changed. We assembled a panel of knowledgeable tax practitioners in the space to discuss how these changes came about and…
The Presumption of Correctness
A pesky problem in state tax law
A common question tax directors ask when considering whether to litigate a state tax case is, What is the likelihood we will win? It’s an obvious question to ask, but an impossible one to answer. In our own experience, we have won cases we’d thought were stacked against us and…
TEI Launches Thought Leadership Bulletin
TEI is excited to announce the launch of a new member benefit, the Thought Leadership Bulletin. The Thought Leadership Bulletin is a biweekly electronic newsletter featuring a compilation of curated content from TEI’s sponsors in different areas of tax. Over twenty sponsors participated in the Thought Leadership Bulletin’s inaugural edition.…
Hosts Sixth Annual Scholarship Golf Outing
On August 1, the TEI Cleveland Chapter hosted its sixth Annual Scholarship Golf Outing at Signature of Solon Country Club in Solon, Ohio. This year’s outing included twenty-two teams sponsored by fifteen firms. Proceeds from the golf outing support scholarships for students who have an interest in a career in… Read more »
Technical Corrections to the 2021 Final Foreign Tax Credit Regulations
Correcting the uncorrectable?
As readers are well aware, almost a year ago, on December 28, 2021, the Treasury Department issued final foreign tax credit regulations (hereafter the “final regulations”)1 finalizing the proposed regulations that Treasury had issued the prior year.2 On July 26, 2022, Treasury issued two sets of technical corrections to the…
Acknowledgments
TEI gratefully acknowledges the support of its sponsors. Their financial support enables TEI to maintain a rich program of value-added education, networking, and advocacy activities for the in-house tax community. Exclusive Affinity Partner Thomson Reuters Platinum ADP, Inc. Andersen Avalara Baker McKenzie Bloomberg Tax & Accounting Crowe LLP CSC Corptax… Read more »
TEI’s State & Local Tax Committee Undertakes Work on Policy Statements
TEI’s State and Local Tax Committee has developed an extensive set of policy statements reflecting TEI’s position on important administrative and procedural issues. These statements facilitate advocacy by providing formal position papers TEI’s members can use when communicating with taxing agencies. The State and Local Tax Committee recently revised a… Read more »
2022 State Corporate Rate Reductions
In 2022, as of mid-July seven states have enacted legislation that reduces their corporate income tax rates, according to the Tax Foundation. Those states, along with their rate decreases and high-level provisions, are highlighted below. For more information on this year’s changes to state tax rates across the United States,… Read more »
Continuing Education Calendar
2022 77th Annual Conference October 23–26 Scottsdale, AZ 2023 Mergers & Acquisitions Seminar February 6–7 Nashville, TN 73rd Midyear Conference March 19–22 Washington, DC Tax Technology Seminar April 24–28 TBD Federal Tax Course – Level 1 June 12–15 East Lansing, MI 78th Annual Conference (75th Anniversary Event) October 22–25 New… Read more »
TEI’s New Tax Technology Committee
We are pleased to announce that the TEI Board of Directors elevated the Tax Technology Subcommittee to a full standing committee at the 2022 Annual Meeting of Members. This elevation recognizes the increasing importance of technology within the in-house tax profession as well as the contributions this group has made… Read more »
New Group Pricing Structure One of my key goals for the 2025–2026 fiscal year…
Corporate Apportionment of Partnership Income A decision issued by the Virginia Court of Appeals, FJ…
Certainty by Design Tax executives operate in a world where material transactions cannot…
The Supreme Court Ruling and the Potential for Tariff Refunds: Their Impact on Transfer Pricing When the United States introduced reciprocal tariffs in April 2025,…
2026 State Tax Changes According to the Tax Foundation, forty-three states made significant changes…
The Price of Regulatory Certainty Prior to the Inflation Reduction Act (IRA) of 2022, transferability…