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International Tax in Flux
With more changes coming, what’s your game plan?

At this writing we are in the middle of some of the most significant changes to the international tax landscape in a generation. Many of the coming changes are well reported and obvious, others less so. Although busy professionals have precious little time to consider trends and to plan… Read more »

TEI at Three Score and Thirteen: Respected, Essential-and Evolving
As new leaders inevitably emerge, seasoned professionals say TEI critical to professional, personal growth

Over seventy years ago, a core group of corporate tax professionals met in New York City and created an organization to serve the professional needs of in-house tax executives. Meeting the education, networking, and advocacy needs of business tax professionals has anchored Tax Executives Institute ever since. Over the ensuing… Read more »

Tax Developments in 2016
Part 2: International Tax. A Whole New World for Intangibles

As the year comes to a close, we have a natural tendency to reflect on the past twelve months. This year has been exciting and challenging. Brexit. Summer Olympics. The U.S. presidential elections. This also has been an exciting and challenging year for international tax professionals deciphering recent guidance.… Read more »

Tax Developments in 2016
Part 1: Federal Tax Developments Under Sections 385, 355, and 382; and new rules on partnership audits dominate landscape

This article reviews and analyzes recent law changes and IRS guidance for federal income tax issues this past year. Section 385 Proposed Regulations — Impact on Related-Party Financing Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify… Read more »

TEI Roundtable No. 10: Tax Plans of the Presidential Candidates
Shockingly (Haha), Clinton and Trump Proposals Differ Dramatically

This is not your typical presidential election season. So, as we prepare this issue of the magazine, tax issues are not on the front burner. Who knows what will happen during the debates or as the campaign heads inexorably toward Election Day? For this roundtable, we convened a group of… Read more »

Sauce for the Goose: Standards Applicable to Taxpayers, Practitioners — and the IRS
The contention among the parties results not from a lack of reasonable standards, but rather from an apparent failure by some IRS personnel to follow those standards in practice and the relative lack of accountability.

The relationship between the Internal Revenue Service’s Large Business & International (LB&I) Division and its constituent taxpayers is complex, marked by alternating episodes of cooperation and contention. LB&I often invites taxpayers and their representative groups to participate in the agency’s critical self-evaluation and listens closely to suggestions and complaints. At… Read more »

State Aid: What It Is, and How It May Affect Multinationals and Tax Departments
European Commission’s actions against member states bear close scrutiny

Never before has international taxation been in such a spotlight in the business press. Cross-border mergers, international tax policy, and base erosion and profit shifting (BEPS) have each been the subject of major front-page articles in the financial news. Over the last two years another topic has increasingly been in… Read more »

The New LB&I
Recent IRS reorganization raises panoply of significant issues

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… Read more »

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