Author: Tax Executive Staff

Tax Avoidance Rule in Canada Tested in Deans Knight Case
The Expert: Steve Suarez

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Question: What does the Supreme Court decision in Deans Knight mean for tax professionals? The general anti-avoidance rule (GAAR) in Canada’s Income Tax Act applies when a taxpayer undertakes transactions whose primary purpose is to obtain a tax benefit, in a way that abuses or misuses one or more provisions…

TEI Comments on Canadian Draft RUTT Form

On June 7, TEI submitted comments to the Canada Revenue Agency (CRA) regarding the draft Reportable Uncertain Tax Treatment (RUTT) form. Taxpayers must use the RUTT form to report certain items depend-ing on how those items are treated on a taxpayer’s relevant financial statements. TEI’s comments focused on recommendations to… Read more »

TEI’s New Student Committee

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We are pleased to announce that TEI’s board of directors has approved the addition of a Student Committee at the 2023 Annual Meeting of Members. This appointment recognizes the increasing importance of inspiring students to pursue careers in taxation and acknowledges the efforts of TEI’s student members to launch TEI’s… Read more »

Administrative Challenges Multistate Businesses Face—and Potential Solutions
Sales and use taxes impose idiosyncratic—but fixable—burdens on businesses

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Since the beginning of time, multistate taxpayers have faced significant administrative challenges to complying with all the variations in state and local tax laws. If “the beginning of time” may be a bit of a stretch, those challenges are a reality today. And any business that operates in multiple states…


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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 Baker McKenzie Bloomberg Tax & Accounting Crowe LLP CSC Corptax Deloitte… Read more »

IRS Formalizes Process for Evaluating Advance Pricing Agreement Requests
Practical effects remain to be seen

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The Internal Revenue Service has issued interim guidance on the process the Advance Pricing and Mutual Agreement Program (APMA) will follow when determining whether to accept taxpayer requests for an advance pricing agreement (APA).1 Existing guidance already states that APMA has discretion to reject an APA request and identifies some…

Continuing Education Calendar

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  2023 2023 Annual Conference (75th Anniversary Celebration) October 22-25 New York, NY Federal Tax Course – Level 1 Simulative November 6-January 16   virtual US International Tax Course Simulative November 8-January 18   Virtual Tax Technology Seminar Update November 28-30   Virtual Federal Tax Course-Level 2 Simulative January 23-February… Read more »

Excising Stock Buybacks From the Corporate Playbook
How will the excise tax be applied to taxpayers in light of the statutory language, Notice 2023-02, and Announcement 2023-18?

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On August 16, 2022, the Inflation Reduction Act of 2022 (the IRA) was signed into law.1 Among a number of changes the IRA introduced to the Internal Revenue Code of 1986 was a new excise tax imposed on what are commonly referred to as stock buybacks by publicly traded corporations.…