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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 »

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 »

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 »

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 »

Your Complete Pillar Two Playbook
Follow these steps to tackle complexity, allocate resources, automate new processes, and more

Today’s resource-challenged tax departments often find it necessary to focus on what’s most critical. Although the release of the Pillar Two model rules captured attention, its adoption remained uncertain until things abruptly changed at the end of 2022, when three events occurred: The European Union unanimously agreed to a directive… Read more »

Sales Tax and the M&A Process
Understanding the entire journey—from diligence through post-transaction

Mergers and acquisitions (M&As) play an active role in the corporate landscape, facilitating growth, consolidation, and strategic realignment among businesses. Companies often include M&A activity in their short-term and long-term strategies. To successfully navigate M&As, tax directors and chief financial officers identify areas that tend to present pitfalls that can… Read more »