Features
Intercompany Transactions: Current State Tax Developments
Nexus and documentation are key issues in understanding the current intercompany transaction legal landscape
Intercompany transactions can be used to shift income from entities with a physical nexus in many states to a related member with a limited nexus in favorable taxing jurisdictions. In moving to combat the benefits received from such intercompany transactions, states tend to employ one or more of the following… Read more »
LB&I Audits: Old Lessons, New Approach
Transparency, Collaboration, Fair and Efficient Resolution: No Argument with Goals, but the Devil Is in the Implementation Details
Those who ignore history are doomed to repeat it. That adage is true in all walks of life, but it is particularly appropriate as the IRS prepares to implement its most recent initiative for examinations by the Large Business & International division (LB&I), as described in the draft release of… Read more »
TEI Roundtable No. 2:
Flexible Work Arrangements Provide New Choices for Tax Professionals
Flexible work arrangements have been around for several decades now but—with the Internet and laptops and the rise of millennials—have become more prevalent for many professionals, including tax executives. For our second TEI Roundtable, we convened a conference call in January 2015 moderated by Tax Executive Senior Editor Michael Levin-Epstein… Read more »
TEI Roundtable No. 1
The Wynne Case
In November 2014, the U.S. Supreme Court heard oral argument in Maryland State Comptroller of the Treasury v. Brian Wynne, et ux. The case involved a particular provision of a Maryland tax statute, which, according to the plaintiff, violated the dormant interstate Commerce Clause of the U.S. Constitution and potentially… Read more »
The Fringe Benefit Rules Applicable to Protecting Executives Since the 2024 murder of Brian Thompson, the CEO of…
TEI Roundtable No. 53: Using AI for Tax Law Research As artificial intelligence continues its scorching rise, in-house tax professionals…
Zooming In on Tax Provision Software’s Biggest Benefit It’s no secret that the annual income tax provision is…
Opportunity Knocks: Resolving Tax Issues in the Current IRS Environment Decades of underfunding and hiring freezes have thoroughly depleted the…
Nurturing the Future of TEI My presidency came at a pivotal time for TEI and…
The View From Above Authors’ note. This article was prepared on April 22, updated…