Departments and Columns
Throwbacks (and I Don’t Mean Old Tax Lawyers) Are Awful
It’s no revelation that I think state corporate income taxes are ineffective and inefficient ways to raise revenue. For a wide variety of reasons, taxes on corporate profits don’t work all that well. Many defend corporate levies in the belief that corporations use services and should pay. But this benefits… Read more »
An End-of-Examination Checklist
The Expert: S. Starling Marshall
Nearing the end of an Internal Revenue Service exam cycle can feel like time to wrap up the process quickly and move on to the next task and then the next cycle. However, considering a few things to do now can result in a faster, more successful resolution of issues… Read more »
67th Midyear Conference Photo Highlights
TEI in Action
One of the privileges of serving as TEI’s international president is having the opportunity to visit chapter leaders and members in different parts of the world—in short, to watch TEI in action. So, just before the holidays, I was delighted to lead a delegation of members and staff to our… Read more »
European Union State Aid Investigations
Since June 2013, the European Commission (Commission) has been investigating the tax ruling practices of European Union member states, and in December 2014 it extended this information inquiry to all member states. During these investigations, the Commission analyzed whether tax rulings granted selective advantages to specific companies. Article 107(1) of… Read more »
State Tax Matters for Foreign Corporations
The Experts: Maria Todorova and Eric J. Coffill
The Experts: Maria Todorova and Eric J. Coffill Even though state taxation has moved away from the worldwide unitary method, with Alaska being the only state currently requiring use of the worldwide unitary method and only then regarding oil and gas corporations, there are still many situations where non-U.S. companies… Read more »
Emerging Leader: Michell Rodriguez
For many people, Costco is their favorite store. For Michell Rodriguez, it’s her favorite (and current) employer, and she appreciates working there as much as if not more than customers enjoy shopping there. Here’s how Rodriguez, director of corporate tax, describes working at Costco: “I work for and with really… Read more »
A Little Rebellion Now and Again
Over two hundred years ago, Thomas Jefferson observed that “a little rebellion every now and then is a good thing.” Well, there are rebellions and then there are rebellions. The recent 2016 presidential election arguably belongs in that second category, with its pushed envelopes, destroyed conventions, and overturned expectations about… Read more »
Emerging Leader: Dorothy O’Shea
“When I graduated from university with a bachelor of commerce degree with a major in accounting, I would never have imagined that my career path would have led me to spending the majority of my career in tax,” Dorothy O’Shea says. But O’Shea, currently head of tax for General Mills… Read more »
Jim Kennedy
For Jim Kennedy, there was little doubt that his calling was to be a tax professional. In law school, Kennedy took every tax course he could and wrote a comment for the University of Pittsburgh Law Review on safe harbor leasing under ERTA and TEFRA. “This interest in tax legislation… 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…
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…
Certainty by Design Tax executives operate in a world where material transactions cannot…
The Price of Regulatory Certainty Prior to the Inflation Reduction Act (IRA) of 2022, transferability…