Features
Unfair Apportionment: Consider the Alternatives
The taxpayer’s task is to assess both constitutional and statute-based options
When must state apportionment be fair? Always. If a state’s normal apportionment formula is operating unfairly with respect to your company, you need to consider the alternatives. The United States Supreme Court has articulated a four-part test for determining whether a state tax burdens interstate commerce in violation of the… Read more »
Nexus Is Crucial, Complex Connection for State Tax Professionals
After financial crisis, states enacted broader laws to increase revenues
Nexus is a wondrous word, replete with meanings. A quick search turns up all kinds of interesting uses. Nexus is a cell phone, it is a type of android from the movie Blade Runner, and it appears in the names of songs, bands, and albums. It is a superhero, the… Read more »
TEI Roundtable No. 13: Ethics and Tax Planning
In the end, tax planners must be comfortable explaining to taxpayers how they report transactions
Tax planning and ethics. For some corporate tax practitioners, the combination is not exactly like the perfect martini, but more like the perfect storm. However, like it or not, both are extremely important when advising clients about tax issues. For this roundtable, we convened a group with a world of… Read more »
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 »
Q&A With Robert Stack
Robert Stack served as deputy assistant secretary for international tax affairs in the Office of Policy at the U.S. Department of the Treasury for almost four years before deciding to leave government service. During his tenure, Stack responded to numerous questions from TEI members and recently granted Tax Executive… Read more »
TEI Roundtable No. 12: The Evolving Education of Tax Professionals
Trying to meet corporate needs for more well-rounded students in changing times
The education of tax professionals has never been as important—or as complex. Tax laws and regulations are proliferating, the international tax scene is burgeoning, online education is on the rise, and, according to some observers, many students expect different educational experiences. In November, we convened a roundtable to explore these… 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 »
TEI Roundtable No. 11: What Keeps CTOs Up at Night
Retroactivity issues and the Apple case may trigger some angst, but what often cause concern for CTOs on the firing line are business developments they don't know about
For chief tax officers (CTOs), there are everyday worries, and then there are worries that keep them up at night—BEPS, changing compliance requirements, and increasing demands on their time, to name just a few. Tax Executive convened a roundtable to discuss in more detail the changing role of CTOs… 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 »
New Group Pricing Structure One of my key goals for the 2025–2026 fiscal year…
Corporate Apportionment of Partnership Income A decision issued by the Virginia Court of Appeals, FJ…
2026 State Tax Changes According to the Tax Foundation, forty-three states made significant changes…
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…