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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 »

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 »

Preparing Now for 2025 Tax Legislative Activity
Looking ahead to the Trump administration and tax implications

Editor’s note: This article was finalized prior to President Donald Trump’s imposition of tariffs on Canada, Mexico, and China. January marked the beginning of the 119th Congress and President Donald Trump’s return to the White House. With full Republican control of the legislative and executive branches of government, Republicans are… Read more »

TEI Roundtable No. 49: A Look at the TCJA in 2025
With sunsetting provisions on the horizon, taxpayers hope for greater visibility

Editor’s note. This conversation was recorded in August, prior to the U.S. presidential election. Despite the election of Donald Trump in November, uncertainty remains surrounding the Tax Cuts and Jobs Act. No matter how the US election pans out in November, the new administration will have its hands full addressing… Read more »

The Rise of the Excise Tax
Final and proposed regulations for the excise tax on stock repurchases

In August 2022, Public Law No. 117-169—commonly called the Inflation Reduction Act of 2022—enacted Section 4501 of the Internal Revenue Code.1 The statute generally imposes a nondeductible one percent excise tax (the “excise tax”) on the net value of share repurchases by publicly traded domestic corporations in a given tax… Read more »

State and Local Tax Implications for a Remote Workforce
As remote work becomes more common, withholding and nexus are among key considerations

State and local tax issues related to remote workforces have existed for many years. However, the pandemic—with the attendant drastic increase in employees working from home or elsewhere—has intensified these issues and brought them to the forefront of taxpayers’ attention. The remote work trend continues even as we emerge from… Read more »

TEI Roundtable No. 46: My Tax Journey, Part One
Tax professionals share insights into their unique journeys and roles

No two journeys toward a career in tax are the same. Just ask the panelists from TEI’s My Tax Journey session at the Annual Conference last fall. For this issue’s Roundtable, we reconvened the panelists to gather more of their perspectives. They are Josephine Scalia, head of tax at… Read more »

It’s a Celebration!
TEI takes to the Big Apple for its diamond anniversary milestone

TEI descended on the New York Marriott Marquis in Times Square to celebrate its seventy-fifth anniversary at the Annual Conference in October. More than 500 registrants, including members from around the world, 175 speakers, more than seventy sponsor firms, and TEI’s entire staff joined to participate in this special occasion.… Read more »

TEI Roundtable No. 45: The 2023 Survey of Chief Tax Officers
Does your company have a tax technologist?

Chief tax officers (CTOs) are integral to the fabric of TEI, with their own roundtable discussion group and their participation in all aspects of the organization. Recently, TEI held a CTO discussion group session regarding the role and prevalence of tax technologists and surveyed CTOs on several issues, including whether… Read more »

TEI Roundtable No. 44: Leadership Development and Succession Planning
One critical factor is finding high-potential candidates on the team

As we’ve learned from the fabulous TV series Succession, leadership development and succession planning can often get a little, shall we say, dicey. Fortunately, in the tax realm, it doesn’t get quite as chaotic as in the Roy family. To find out more about best practices in our profession, we… Read more »