Features

Part II: GILTI, FDII, and FTC Guidance and International Tax Planning
How to decipher this complex stew, replete with interesting ingredients

Prior to tax reform, multinational businesses often had similar strategies with respect to outbound international tax planning. Given the high U.S. corporate tax rates and worldwide system of taxation, many businesses sought to earn and keep profits offshore to defer U.S. tax. When it was important to repatriate profits, foreign… Read more »

Part I: The Graphic Guide to Section 163(j)
A visual breakdown of this important aspect of the TCJA

As children, we learned new and difficult concepts, such as our first words, by associating them with pictures. Who could forget the Dr. Seuss classic Hop on Pop? In this article, we take you back to your childhood by offering a series of pictures to simplify the most significant aspects… Read more »

TEI Roundtable No. 23 Transitioning to a New Job
Let’s face it, it’s a weird mix of excitement and anxiety

For anyone, in any field, finding and transitioning to a new job is an intense experience—somewhat exhilarating, somewhat scary. We wanted to find out what the experience was like for seasoned TEI members, two of whom recently transitioned into new jobs: Louis Mestier, now vice president of tax for Eldorado… Read more »

Administrative Guidance, Ethical Standards, and Tax Return Positions
In-house tax professionals must traverse a difficult course

Many corporations currently face tremendous high-value tax uncertainty as a result of the 2017 Tax Cuts and Jobs Act (TCJA), not to mention other longstanding tax risks such as transfer pricing. For some tax executives, these risks constitute familiar waters. For other tax executives, however, navigating these risks is less… Read more »

TEI Roundtable No. 22: Developing a TCJA Checklist
International issues, software selection, and involvement of tax technologists all play key roles in a complicated process

The Tax Cuts and Jobs Act is not “new” anymore. But compliance with an ever-evolving set of regulations and guidance is still on the front burner for corporate tax professionals—and is likely to stay there for quite a while. As with so many tax issues, the best way to ensure… Read more »

Tax Legislation in the 116th Congress—What to Look For
Ways and Means Committee hearings on TCJA may offer advocacy opportunities

Conventional wisdom says that Wall Street likes divided government, but should tax directors feel the same way? Now that the new Congress has been sworn in and is beginning its work, businesses must attempt to determine what the prospect is for tax legislation in the 116th Congress with a Democratic… Read more »

Taxable Nexus: Moving Toward an Economic Approach
Corporate tax professionals might consider OECD approach

In this article we discuss the global trend toward taxing foreign companies with significant business abroad that have managed, by dodging local permanent establishment requirements, to remain outside the tax net in the countries where they do business. In particular, we discuss the recent trend whereby taxing authorities have significantly… Read more »

Tax Avoidance vs. Tax Evasion
What every tax director needs to know about criminal tax fraud

Reducing tax liability is a top priority for every corporate tax department. But that priority must be tempered by tax compliance obligations. Increasingly complex business relationships and transactions—often accompanied by increasingly complex tax planning—can leave even the most sophisticated tax practitioners wondering how the Internal Revenue Service will react to… Read more »

TEI Roundtable No. 21: TCJA Implementation: A View From the Trenches
Dealing with landmark legislation takes a special kind of planning

Tax Cuts and Jobs Act (TCJA) implementation, compliance, and planning is a work in progress. How are tax professionals in the trenches dealing with this landmark legislation? To find out, we convened a roundtable of experts including Stephanie Kuykendall, vice president and general tax counsel at Shell Oil Company; Jason… Read more »

Wayfair: Practical Implications for the Business World
Now companies must go beyond tracking where salespersons and property go to make proper nexus determinations

In the wake of the U.S. Supreme Court’s June 21, 2018, decision in South Dakota v. Wayfair, the business world has changed dramatically. In determining that, under certain conditions, a state could require a remote seller to collect and remit sales and use tax liabilities, the Court overturned its own… Read more »

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