Features
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 »
State and Local Tax Implications for a Remote Workforce
As remote work becomes more common, withholding and nexus are among key considerations
State and local tax issues related to remote workforces have existed for many years. However, the pandemic—with the attendant drastic increase in employees working from home or elsewhere—has intensified these issues and brought them to the forefront of taxpayers’ attention. The remote work trend continues even as we emerge from… Read more »
Brief Overview of What the Pillar Two Directive Means for Multinational Companies
Pillar Two’s inconsistent adoption by EU member states could complicate an already intricate system of domestic and EU laws that businesses must navigate
Editor’s note: This article was written prior to the OECD’s new administrative guidance on Pillar Two, released June 17. This article examines two central points for multinational enterprises as they grapple with the complexities and novelties of Pillar Two. We first address nuanced interpretations of various points of guidance and… Read more »
Tax Valuation Considerations for M&A Transactions
A close look at purchase price allocations, Section 382 limitation calculations, tax receivable agreements, and more
Public corporations, private equity-backed portfolio companies, and privately held companies often look to mergers and acquisitions (M&As) to drive growth and shareholder value. However, pursuing M&A-driven growth may be complicated, since companies must comply with ever-evolving financial and tax reporting requirements, deal with increasing financial audit and tax authority scrutiny,… Read more »
TEI Tax Technology Seminar Set to Deliver Once Again Each year, TEI’s Tax Technology Seminar brings together in-house tax…
Sales Tax Traps for Disregarded Entities Sales tax rules can be confusing, because states often take…
Overreliance on AI for Tax Advice: A Cautionary Perspective With the increasing popularity of artificial intelligence (AI), many people…
How Is Tax Policy Shaping the Future of Clean Energy Investment? US electricity demand is accelerating at a pace few anticipated.…
Considerations in Tax Refund Litigation The Internal Revenue Service has seen unprecedented changes this year.…
The Unconstitutionality of the Brazilian QDMTT On December 30, 2024, the government of Brazil published Law…