On November 30, HM Revenue & Customs (HMRC) issued new interpretive guidance on the UK’s diverted profits tax (DPT) found in Part Three of the Finance Act 2015, which is intended to apply to large multinational enterprises (MNEs) with business activities in the UK that enter into “contrived arrangements” to… Read more »
Tax Executives Institute is an organization made up of varied in-house tax professionals, and there’s no event like a conference to take stock of how the distribution works out. We examined the attendee data* to give you a look at who makes up the TEI membership. (*Data current based on… Read more »
The Bipartisan Budget Act of 2015, signed into law November 2, 2015, repealed the long-standing audit and litigation procedures for partnerships that had been enacted in the Tax Equity and Fiscal Responsibility Act of 1982 and created a statutory framework for new partnership audit rules. The new partnership audit rules…
The OECD’s Base Erosion and Profit Shifting (BEPS) initiative is progressing toward a crucial phase during which U.S. policymakers will balance its priorities with their own agendas. This initiative will doubtlessly create new concerns as well as new opportunities for multinational companies whose businesses transcend borders. But necessary preparation for… Read more »
In her first two years at the University of Texas, Katrina Welch was a petroleum engineering major and worked as a roustabout in an oil field during the summer. Perhaps that rugged experience helped pave the way for what Welch is doing today—serving as vice president and head of tax… Read more »
Tax Executives Institute has implemented several initiatives aimed at increasing participation among emerging tax professionals, including the formation of an Emerging Tax Professionals Subcommittee. Tax Executive convened a roundtable discussion, moderated by Senior Editor Michael Levin-Epstein, to find out what the subcommittee was doing and the ways emerging tax professionals… Read more »
In 1991 the Internal Revenue Service (IRS) established the Advance Pricing Agreement (APA) program, allowing a taxpayer to request that the IRS, and potentially other countries, prospectively approve its transfer pricing facts, transfer pricing methodology, and arm’s-length range of results. The certainty provided by this prospective approach, combined with the…
On July 27, the Tax Court issued a unanimous opinion1 in Altera Corporation v. Commissioner, 145 T.C. No. 3 (2015), in which the court held that Treas. Reg. § 1.482-7(d)(2) is invalid. It is relatively rare for a court to invalidate Treasury regulations, and, for that reason alone, the decision…
For a large majority of business taxpayers and their in-house tax professionals worldwide, the Large Business & International Division (LB&I) of the Internal Revenue Service (IRS) represents the principal point of regular interface with the U.S. taxing agency. Thus, any changes, whether large or small, in scope, focus, or operation…
In 2016, Tax Executives Institute anticipates increased engagement online with established and new members alike. The first step is the new TEI website, which is currently in development. But there are also opportunities for TEI chapters to use their voices in the Twitter-sphere and other social media domains outside of… Read more »
