Features
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 »
The Credit We Love to Hate
How to ease the pain of R&D tax credits
We’ve all been taught not to raise certain topics at work, among them religion and politics, to name just two. They are polarizing and could even be career-ending, depending on whom you engage with or how the conversation goes. What about water-cooler topics like traffic, Mondays, audits, or R&D tax… Read more »
The Votes Are In: State Responses to Federal Tax Reform
TCJA’s impact on states poses practical concerns and challenges
H.R. 1,1 colloquially known by its former name, the Tax Cuts and Jobs Act (TCJA), made sweeping changes to the Internal Revenue Code and has far-reaching implications for state tax systems that broadly conform to the IRC. This article highlights state legislative and administrative responses to the TCJA as well… Read more »
TCJA—So Many Questions, So Little Time
Law leaves significant open questions for Treasury and the IRS to answer
On December 22, 2017, President Trump signed into law the act commonly referred to as the Tax Cuts and Jobs Act (TCJA, PL 115-97). Like much tax legislation, the TCJA provides a legislative framework but leaves a significant number of questions to be answered by the Treasury Department and the… Read more »
New Group Pricing Structure One of my key goals for the 2025–2026 fiscal year…
2026 State Tax Changes According to the Tax Foundation, forty-three states made significant changes…
Corporate Apportionment of Partnership Income A decision issued by the Virginia Court of Appeals, FJ…
The Price of Regulatory Certainty Prior to the Inflation Reduction Act (IRA) of 2022, transferability…
The Supreme Court Ruling and the Potential for Tariff Refunds: Their Impact on Transfer Pricing When the United States introduced reciprocal tariffs in April 2025,…
Masha Freyvert When Masha Freyvert was an undergraduate at Boston University, she…