Features
Renewable Energy Tax Credits After the Inflation Reduction Act
Successes, challenges, and the impact of the 2024 election
Following the the 2024 US general election, with Donald Trump’s victory, the future of the Inflation Reduction Act (IRA) enters a pivotal phase. Enacted in 2022, the IRA has been a cornerstone of the United States’ renewable energy strategy, offering tax incentives to drive investments in technologies like wind, solar,… Read more »
Inequitable Barriers to Equitable Apportionment
When petitioning for equitable apportionment, taxpayers face motley state-imposed obstacles
Every state that imposes a corporate income tax requires multistate businesses to apportion business income. The states’ methods of apportioning income, however, vary considerably and can produce inconsistent results. The United States Supreme Court sanctioned these differences in Moorman Mfg. Co. v. Bair1 when the Court allowed Iowa to deviate… Read more »
Who Is the Customer?
The ins and outs of market-based sourcing
Compared to the complexity of cost-of-performance (COP) sourcing of services for income tax purposes, a market-based approach to apportionment sounds downright simple. Instead of comparing the location of all payroll and material costs of generating revenue as in a COP calculation, for market-based sourcing one looks only to the location… Read more »
Prepare for Public Country-by-Country Reporting
Getting ahead of risks to reputation
With public country-by-country reporting (CbCR) on the horizon, companies with operations in Europe or Australia may soon have to disclose key information about their tax and business operations by jurisdiction. Companies with operations in Romania may be required to produce public CbCR filings as early as December 31, 2024 (for… Read more »
Q&A With Jim Bearden
Get a glimpse into the mind of a man built to lead—the right way
Jim Bearden is a former Marine officer and an expert on accountability in leadership—and he’ll be at TEI’s 79th Annual Conference this fall. There, Bearden will engage with attendees in a keynote address and a breakout session to help them develop better, culture-focused leadership habits. In lieu of the Roundtable… Read more »
The Rise of the Excise Tax
Final and proposed regulations for the excise tax on stock repurchases
In August 2022, Public Law No. 117-169—commonly called the Inflation Reduction Act of 2022—enacted Section 4501 of the Internal Revenue Code.1 The statute generally imposes a nondeductible one percent excise tax (the “excise tax”) on the net value of share repurchases by publicly traded domestic corporations in a given tax… Read more »
Key Challenges and Opportunities for Tax Directors in a Tightening Economy
Maximize tax savings but tread carefully with debt restructurings
Navigating a tightening economic cycle—characterized by prolonged high interest rates and uncertainty about future rate cuts—requires care and foresight. In the current financial climate, companies tend to accrue substantial net operating losses (NOLs), tax credits, and other tax assets and face deteriorating investments in their subsidiaries. Debt modifications and forbearances… Read more »
Meeting Pillar Two Calls for Tax Transformation and Single-Solution Efficiencies
Unified corporation-wide tax solutions permit tax strategizing rather than mere compliance and reactivity
A wait-and-see attitude characterizes this year’s global tax landscape, with the emergence of regulations like BEPS Pillar Two marking a pivotal moment. Designed to address base erosion and profit shifting, BEPS Pillar Two proposes a framework to establish a minimum global corporate tax rate. This initiative signifies a concerted effort… Read more »
TEI Roundtable No. 48: AI Implementation in Today’s Tax Landscape
A panel from TEI’s Tax Tech Seminar reconvenes to keep the conversation going on the evolution of artificial intelligence in tax
As artificial intelligence (AI) gains traction throughout the business world, tax is in the thick of it, aiming to take advantage of AI’s benefits while navigating the attendant complexities. At TEI’s Tax Technology Seminar held this spring in Orlando, one session spoke to those issues at length—an engaging conversation and… Read more »
Pillar Two and IRS Notice 2023-80
Offering clarity on QDMTTs and top-up taxes
Internal Revenue Service Notice 2023-80 (hereinafter “the notice”) provides the US government’s view on the foreign tax credit treatment of Pillar Two top-up taxes and makes a clear distinction between qualified domestic minimum top-up tax (QDMTT) and the extra-jurisdictional top-up taxes imposed by an income inclusion regime (IIR) and the… Read more »
Managing Canadian Tax Risk The global tax environment has seen fundamental changes in recent…
Transfer Pricing in Transition Although states experienced significant tax revenue growth during the COVID-19…
The One Big Beautiful Bill Act In July 4, President Donald Trump signed into law the…
Automation in Action: Key Takeaways From the TEI Automation Competition In February, tax professionals from across the country gathered in…
Beyond Automation: Why Having a Human in the Loop Is Critical for Sales Tax Compliance The allure of sales tax automation is undeniable. Many companies,…
TEI Holds Third International Tax Student Case Competition TEI held its third International Tax Student Case Competition at…