Features

Trends and Developments in Canadian Tax Controversy and Jurisprudence
Transfer pricing issues, increases in voluntary disclosures, and procedural disputes are among major developments, but what will happen in 2016 — and beyond?

The Canada Revenue Agency (CRA) continues to employ a risk-based approach when auditing large corporate taxpayers, focusing on high-risk areas such as aggressive tax avoidance and international tax planning. Information-gathering involves the use of written requests and requirement letters to routinely attempt to compel delivery of taxpayer information. However, the… Read more »

Canadian Sales Tax Reform
How the U.S. Neighbor to the North Transitioned From a Multistage Sales Tax to an Almost Fully Harmonized Single VAT — in Just One Century

The problem with good tax policy is that politics always gets in the way. And for the United States—a country whose sales tax system (at least from a nonresident’s perspective) cries out for reform—your neighbor to the north and our experience may offer a cautionary tale of inspiration. After all,… Read more »

TEI Roundtable No. 9: Six Past TEI Presidents From Canada Share Their Stories
Spanning Four Decades, There’s a Lot to Learn From These Former Head Honchos

In this special issue focused on Canada, it seemed only appropriate that the Roundtable we convened also reflect a Canadian bent. To that end, we invited the six living TEI presidents from Canada to discuss their tenures at the helm of the organization, including Vincent Alicandri (2008–09), David Burn (1986–87),… 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 »

States Fine-Tune Market-Based Sourcing Rules Through Regulation
The devil is in the details in this complex, emerging issue

In 2015, the rubber met the road, and states began to accelerate the adoption of detailed regulations to accompany what is often vague statutory language to source receipts from the sale of services and intangibles based on the location of the “market.” In this article, we survey the key proposed… Read more »

Deploying Company Foundations in Battle for Tech Talent
Managing compliance issues, planning opportunities for tax departments are key concerns

With top companies in Silicon Valley and elsewhere engaged in heated competition to fill the increasing number of open job positions requiring technical skills, initiatives to expand the country’s pipeline of science, engineering, and technology talent is becoming a renewed priority for corporate philanthropy. Corporate tax departments have an important… Read more »

TEI Roundtable No. 8: Tax Talent in Transition
How to plan your next steps in the face of M&As, spinoffs, bankruptcies, outsourcing, and changing demographics

The days when a young tax professional at a corporation worked his or her way up the ladder and stayed with the same company for an entire career are falling by the wayside. True, those days are not disappearing entirely, but most tax professionals move among several different opportunities at… Read more »

TEI Roundtable No. 7: Engaging Emerging Tax Professionals

Tax Executives Institute has implemented several initiatives aimed at increasing participation among emerging tax professionals, including the formation of an Emerging Tax Professionals Subcommittee. Tax Executive convened a roundtable discussion, moderated by Senior Editor Michael Levin-Epstein, to find out what the subcommittee was doing and the ways emerging tax professionals… 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 »

Altera Deconstructed: A Nuanced Alteration in Tax Law
Tax Court’s Unanimous Opinion Deals With Unusual Regulatory Situation

On July 27, the Tax Court issued a unanimous opinion1 in Altera Corporation v. Commissioner, 145 T.C. No. 3 (2015), in which the court held that Treas. Reg. § 1.482-7(d)(2) is invalid. It is relatively rare for a court to invalidate Treasury regulations, and, for that reason alone, the decision… Read more »

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