Tax Avoidance Rule in Canada Tested in Deans Knight Case
The Expert: Steve Suarez
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
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
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…
TEI Holds Its Inaugural International Tax Student Case Competition
On August 19, TEI held its inaugural International Tax Student Case Competition in Montreal. Five teams of four students each from universities in North and South America competed to determine which team could devise the best solution to a set of international tax issues. The Case Competition was the brainchild… Read more »
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 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
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…
TEI Comments on Proposed Revisions to Canadian APA Program
On July 21, the Institute filed comments with the Department of Finance Canada regarding Information Circular 94-4R2, International Transfer Pricing: Advance Pricing Arrangements. TEI’s comments included concern about the undue compliance burden the Circular proposes to impose on taxpayers, its unreasonable filing deadlines, and the additional requirements for renewing an… Read more »
Continuing Education Calendar
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?
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 to Comment on New Proposed Section 987 Regulations The US Treasury Department and Internal Revenue Service published new…
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 Welcomes New Staff, Promotes Team Member Erica Larkin Erica Larkin joined TEI in November as the…