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The Fringe Benefit Rules Applicable to Protecting Executives
What security measures are excludable from executives’ income?

Since the 2024 murder of Brian Thompson, the CEO of UnitedHealth Group’s insurance division, employers are reexamining their corporate security policies, which are designed to protect employees, including executives, from harm. The law is clear that the value of personal protection benefits provided to employees may be excluded from income… Read more »

TEI Roundtable No. 53: Using AI for Tax Law Research
How tax professionals can thoughtfully leverage—and embrace—the acceleration of artificial intelligence

As artificial intelligence continues its scorching rise, in-house tax professionals are turning to it more frequently to gain workflow efficiencies. One particular area in which AI can do just that is tax law research—if done with human oversight. Using AI for research requires careful attention to detail and knowledge about… Read more »

The View From Above
Ten actions Canadian businesses can take to navigate tariff turbulence

Since his inauguration in January, US President Donald Trump has undertaken a series of aggressive actions aimed at challenging the foundations of the global trade system. Chief among them are sweeping tariff measures that have provoked widespread retaliatory responses, strained diplomatic and economic relations, and dramatically altered global trade dynamics.… 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 »

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 »