Features
The View From Above
Ten actions Canadian businesses can take to navigate tariff turbulence
Authors’ note. This article was prepared on April 22, updated on July 15, and is accurate as of that date. Please refer to legal counsel for up-to-date information on the status of the trade and tariff measures between Canada and the United States. Since his inauguration in January, US President… Read more »
Planning for IRS Audits in an Era of Uncertainty
Using the economic substance doctrine as a general anti-abuse rule
In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions.1 For example, last year, the IRS released Revenue Ruling 2024-14,2 establishing its position that the tax effect of certain related-party basis adjustment transactions should be disallowed under… Read more »
Transfer Pricing and Valuation in Financial Transactions
The impact of OECD and IRS guidance on credit rating, debt capacity, and interest rates
Business transactions such as mergers, acquisitions, and reorganizations often necessitate the pricing and valuation of financial transactions. Applying different standards may result in different pricing or valuation for the same financial transaction. Therefore, identifying the appropriate valuation standard is crucial. Companies must comply with ever-evolving financial and tax reporting requirements… Read more »
Preparing for Successful SALT Audits
Most of the work should occur long before the state tax notice arrives
Audit preparedness is crucial, since federal and state agencies have increased auditing to make up for budget deficiencies. In the complex, ever-evolving state and local tax (SALT) landscape, maintaining audit readiness and efficiently managing the audit process can be challenging for businesses, especially for entities operating in multiple tax jurisdictions.… Read more »
TEI Roundtable No. 52: FASB Accounting Standards Update 2023-09—Income Taxes (Topic 740)
A not-so-simple update to required income tax disclosures
As financial reporting evolves, the Financial Accounting Standards Board (FASB) Accounting Standards Update 2023-09—Income Taxes (Topic 740) introduces significant shifts that tax professionals must navigate. To shed light on the practical implications and critical challenges posed by the update, including enhanced data collection requirements, jurisdictional disparities in reporting, workflow adjustments,… Read more »
TEI Roundtable No. 51: The Future Corporate Tax Department
Talent, technology, and complexity underscore the “more with less” environment
As tax moves into the future, in-house professionals are experiencing challenges surrounding much-needed talent, gaps in technology investment and knowledge, and complexity in the global landscape, among others. To uncover how the in-house tax world is facing these challenges head-on, Tax Executive convened a panel of key experts: Stephen Dunphy,… Read more »
Disregarded Payment Loss Regulations Go Final
And they’re undoubtedly controversial
“He that pays last payeth but once.”1 The Biden administration published a flurry of tax regulations in its final days. Most of the final regulations implemented the Inflation Reduction Act, President Joe Biden’s economic legacy. However, one surprise was the finalization of the disregarded payment loss (DPL) regulations (hereinafter the… Read more »
Making Sense of CAMT Complexity
When worlds collide, chaos ensues
The corporate alternative minimum tax (CAMT) under Section 55 of the Internal Revenue Code and related provisions was enacted as part of the Inflation Reduction Act of 2022.1 Its structure as an income tax emanating from book income has resulted in a collision of financial and tax accounting, with the… Read more »
An Overview of the EU Public Country-by-Country Reporting Rules
A comprehensive breakdown, with guidance for preparation
The European Union (EU) has long been at the forefront of furthering corporate transparency and accountability. A significant step in this direction was the introduction of nonpublic country-by-country reporting (CbCR) rules in the EU for fiscal years beginning on or after January 1, 2016.1 The nonpublic CbCR rules require multinational… Read more »
TEI World Tour
International President Josephine Scalia’s travels have been underscored by global engagement and inspiration
TEI International President Josephine Scalia is no stranger to worldwide travel, but this go-around, she got firsthand experiences with the Institute’s global community—in droves. Since August, Scalia traveled from her native Canada, throughout the United States, to the Middle East, and across Asia, with her journey ending in December. “In… 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…
Overlooked in Tax Transformation: Elevating Notice Management to a Core Compliance Control Tax technology has advanced rapidly, with recent coverage highlighting the…
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,…