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Certainty by Design
A practical guide to prefiling agreements, closing agreements, private letter rulings, and tax opinions

Tax executives operate in a world where material transactions cannot wait for litigation to resolve interpretive uncertainty. The Internal Revenue Code is dense, dynamic, and increasingly shaped by subregulatory guidance and administrative interpretation. Although litigation remains the ultimate backstop, most public companies, private equity sponsors, and closely held businesses cannot… Read more »

Clarity in a Changing Climate
In-house tax leaders sharpen fundamentals, leverage technology, and strengthen relationships to manage today’s volatility

When in-house tax professionals encounter uncertainty, it’s important to remember that their companies are facing the same turbulence. “Certainty is something we can never truly have, so for me it’s more about gaining clarity and focusing on what is within our control, amid all the uncontrollable,” says Josephine Scalia, vice… Read more »

Considerations in Tax Refund Litigation
Is refund litigation the path to releasing “stuck” refunds?

The Internal Revenue Service has seen unprecedented changes this year. Approximately 25,000 IRS employees—or twenty-five percent of its workforce—have accepted the deferred resignation or retired or were laid off.1 When we wrote this article in November, the federal government had been shut down for more than four weeks with only… Read more »

OBBBA Modifications to US Taxation of International Income
Changes in the new law affect GILTI, foreign tax credits, and inventory sourcing rules, among other international tax provisions

The One Big Beautiful Bill Act (OBBBA), which was signed into law on July 4, has changed US taxation of multinational businesses. The most notable among these changes are various modifications that relate to the former global intangible low-taxed income (GILTI) regime enacted during the first Trump administration as part… Read more »

US Tariffs: The EU Perspective
Turning tensions into business opportunities

Following his inauguration on January 20, President Donald Trump signaled his intentions regarding trade policy by stating, “I always say ‘tariffs’ is the most beautiful word to me in the dictionary.”1 The Trump administration promptly took action with executive orders, leading to significant tariff measures between, among others, the United… Read more »

TEI Roundtable No. 53: Using AI for Tax Law Research
How tax professionals can thoughtfully leverage—and embrace—the acceleration of artificial intelligence

As artificial intelligence continues its scorching rise, in-house tax professionals are turning to it more frequently to gain workflow efficiencies. One particular area in which AI can do just that is tax law research—if done with human oversight. Using AI for research requires careful attention to detail and knowledge about… Read more »

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 »