Features

Planning for IRS Audits in an Era of Uncertainty
Using the economic substance doctrine as a general anti-abuse rule

In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions.1 For example, last year, the IRS released Revenue Ruling 2024-14,2 establishing its position that the tax effect of certain related-party basis adjustment transactions should be disallowed under… Read more »

Transfer Pricing and Valuation in Financial Transactions
The impact of OECD and IRS guidance on credit rating, debt capacity, and interest rates

Business transactions such as mergers, acquisitions, and reorganizations often necessitate the pricing and valuation of financial transactions. Applying different standards may result in different pricing or valuation for the same financial transaction. Therefore, identifying the appropriate valuation standard is crucial. Companies must comply with ever-evolving financial and tax reporting requirements… Read more »

Preparing for Successful SALT Audits
Most of the work should occur long before the state tax notice arrives

Audit preparedness is crucial, since federal and state agencies have increased auditing to make up for budget deficiencies. In the complex, ever-evolving state and local tax (SALT) landscape, maintaining audit readiness and efficiently managing the audit process can be challenging for businesses, especially for entities operating in multiple tax jurisdictions.… Read more »

TEI Roundtable No. 52: FASB Accounting Standards Update 2023-09—Income Taxes (Topic 740)
A not-so-simple update to required income tax disclosures

As financial reporting evolves, the Financial Accounting Standards Board (FASB) Accounting Standards Update 2023-09—Income Taxes (Topic 740) introduces significant shifts that tax professionals must navigate. To shed light on the practical implications and critical challenges posed by the update, including enhanced data collection requirements, jurisdictional disparities in reporting, workflow adjustments,… Read more »

TEI Roundtable No. 51: The Future Corporate Tax Department
Talent, technology, and complexity underscore the “more with less” environment

As tax moves into the future, in-house professionals are experiencing challenges surrounding much-needed talent, gaps in technology investment and knowledge, and complexity in the global landscape, among others. To uncover how the in-house tax world is facing these challenges head-on, Tax Executive convened a panel of key experts: Stephen Dunphy,… Read more »

Disregarded Payment Loss Regulations Go Final
And they’re undoubtedly controversial

“He that pays last payeth but once.”1 The Biden administration published a flurry of tax regulations in its final days. Most of the final regulations implemented the Inflation Reduction Act, President Joe Biden’s economic legacy. However, one surprise was the finalization of the disregarded payment loss (DPL) regulations (hereinafter the… Read more »

Making Sense of CAMT Complexity
When worlds collide, chaos ensues

The corporate alternative minimum tax (CAMT) under Section 55 of the Internal Revenue Code and related provisions was enacted as part of the Inflation Reduction Act of 2022.1 Its structure as an income tax emanating from book income has resulted in a collision of financial and tax accounting, with the… Read more »

An Overview of the EU Public Country-by-Country Reporting Rules
A comprehensive breakdown, with guidance for preparation

The European Union (EU) has long been at the forefront of furthering corporate transparency and accountability. A significant step in this direction was the introduction of nonpublic country-by-country reporting (CbCR) rules in the EU for fiscal years beginning on or after January 1, 2016.1 The nonpublic CbCR rules require multinational… Read more »

TEI World Tour
International President Josephine Scalia’s travels have been underscored by global engagement and inspiration

TEI International President Josephine Scalia is no stranger to worldwide travel, but this go-around, she got firsthand experiences with the Institute’s global community—in droves. Since August, Scalia traveled from her native Canada, throughout the United States, to the Middle East, and across Asia, with her journey ending in December. “In… Read more »

TEI Roundtable No. 50: Compliance, Preparedness, and Risk After Loper Bright
How are tax departments evolving in its wake?

Following the Loper Bright decision, which effectively reduced the power of federal agencies to interpret ambiguous laws, tax departments are faced with potentially reevaluating compliance, litigation preparedness, and risk management strategies, among other issues. Recently, TEI convened a cadre of experts at its Audits & Appeals Seminar to speak on… Read more »