Features
Heard at the Conference
At TEI’s 75th Anniversary Celebration, we asked attendees and sponsors to tell us what TEI meant to them and to describe the value of the TEI experience. Here’s a sampling of what our fabulous attendees and our equally excellent sponsors had to say.
Global Tax Policy and Controversy Trends
Only one thing is certain—they’re not boring
In an engaging and educational Annual Conference session moderated by Cliff Mangano, chair of TEI’s IRS Administrative Affairs Committee, a panel of experts discussed recent developments and trends in global tax policy and controversy. The experts included Scott Frewing, tax partner in the Palo Alto office of Baker McKenzie, who… Read more »
EMEA Chapter Members Report on OECD Stakeholder Meeting
After more than seventy-five years, TEI’s global influence is, by any measure, enormous. An illustrative example is the recent Organisation for Economic Co-operation and Development (OECD) Stakeholder Day on Global Mobility, in which two members of TEI’s EMEA Chapter, Karine Halimi-Guez, vice president and head of tax at Booking.com, and… Read more »
Tax Credit Transferability and Direct Pay Proposed Under the IRA
Potential for interactions with Section 174 complicate a seemingly simple program
The new tax credits in the Inflation Reduction Act (IRA) mean that more taxpayers will have access to more tax credits in the near future. But recent guidance highlights some uncertainties that taxpayers should be aware of before jumping in. The Treasury Department and the Internal Revenue Service recently released… Read more »
The Deference Doctrine—Its History and Possible Future
The Chevron doctrine has weathered changes since 1984, but the biggest one of all may be on the horizon
The doctrine of administrative deference, established in the Chevron case in 1984, requires deference to an agency’s reasonable interpretation of an ambiguous statute.1 The two-part test for requiring deference first addresses whether “Congress has directly spoken to the precise question at issue.”2 If so, the court must enforce the “unambiguous… Read more »
TEI Roundtable No. 45: The 2023 Survey of Chief Tax Officers
Does your company have a tax technologist?
Chief tax officers (CTOs) are integral to the fabric of TEI, with their own roundtable discussion group and their participation in all aspects of the organization. Recently, TEI held a CTO discussion group session regarding the role and prevalence of tax technologists and surveyed CTOs on several issues, including whether… Read more »
Transfer Pricing Operations and Compliance for In-House Tax Professionals
Even if you’re a smaller organization, don’t assume you won’t be audited or targeted
Transfer pricing has never been more important for in-house tax professionals to address, from compliance and analysis to overall tax planning. However, transfer pricing rules change rapidly and globally, largely as a result of the work of the Organisation for Economic Co-operation and Development (OECD) on the base erosion and… Read more »
Administrative Challenges Multistate Businesses Face—and Potential Solutions
Sales and use taxes impose idiosyncratic—but fixable—burdens on businesses
Since the beginning of time, multistate taxpayers have faced significant administrative challenges to complying with all the variations in state and local tax laws. If “the beginning of time” may be a bit of a stretch, those challenges are a reality today. And any business that operates in multiple states… Read more »
IRS Formalizes Process for Evaluating Advance Pricing Agreement Requests
Practical effects remain to be seen
The Internal Revenue Service has issued interim guidance on the process the Advance Pricing and Mutual Agreement Program (APMA) will follow when determining whether to accept taxpayer requests for an advance pricing agreement (APA).1 Existing guidance already states that APMA has discretion to reject an APA request and identifies some… Read more »
Excising Stock Buybacks From the Corporate Playbook
How will the excise tax be applied to taxpayers in light of the statutory language, Notice 2023-02, and Announcement 2023-18?
On August 16, 2022, the Inflation Reduction Act of 2022 (the IRA) was signed into law.1 Among a number of changes the IRA introduced to the Internal Revenue Code of 1986 was a new excise tax imposed on what are commonly referred to as stock buybacks by publicly traded corporations.… 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…
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,…
Overlooked in Tax Transformation: Elevating Notice Management to a Core Compliance Control Tax technology has advanced rapidly, with recent coverage highlighting the…