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The OECD’s BEPS Final Report
Part I: Introduction and Background 15 Actions, Dozens of Questions Maybe the anticipation didn’t reach that of ardent fans waiting for the trailer to the next Star Wars movie. And maybe it didn’t rival that of passionate followers of Harry Potter breathlessly lining up at midnight to make sure they… Read more »
How To Bind Without Getting in One: Avoiding Controversy Over Signature Authority Issues
It’s late in the day. After weeks of review, it’s time to file an entity classification election for an entity in your company’s structure. The election is due today. You have already carefully analyzed the ramifications of the election. Form 8832 has been drafted, reviewed, and approved. All that is… Read more »
The Impact of Loving and Ridgely on Corporate Tax Practice
Former OPR Director Reflects on Her Tenure at the IRS
Many TEI members are acquainted with the IRS’s Office of Professional Responsibility (OPR) and Karen Hawkins, its director until just a few months ago. In the first day of her new life, Hawkins graciously agreed to talk to Tax Executive about her tenure at OPR and the impact of two… Read more »
Forging Forward — But How Fast and in Which Direction?
Data rules the tax technology roost, elevating professionals who embrace its potential, but the “new normal” is not without its pitfalls
In the world of real estate, it’s all about location, location, and location. In the tax world, it is becoming all about data, data, and data. And whatever facet of tax technology you’re talking about—whether it’s hardware, software, Big Data, the cloud, data storage, or cybersecurity—the data are the key drivers.… Read more »
Intercompany Transactions: Current State Tax Developments
Nexus and documentation are key issues in understanding the current intercompany transaction legal landscape
Intercompany transactions can be used to shift income from entities with a physical nexus in many states to a related member with a limited nexus in favorable taxing jurisdictions. In moving to combat the benefits received from such intercompany transactions, states tend to employ one or more of the following… Read more »
LB&I Audits: Old Lessons, New Approach
Transparency, Collaboration, Fair and Efficient Resolution: No Argument with Goals, but the Devil Is in the Implementation Details
Those who ignore history are doomed to repeat it. That adage is true in all walks of life, but it is particularly appropriate as the IRS prepares to implement its most recent initiative for examinations by the Large Business & International division (LB&I), as described in the draft release of… Read more »
The Price of Regulatory Certainty Prior to the Inflation Reduction Act (IRA) of 2022, transferability…
2026 State Tax Changes According to the Tax Foundation, forty-three states made significant changes…
Playing Ball in the Lone Star Stadium Over the last few years, some top US companies have…
TEI Holds 2026 Midyear Conference in Washington, D.C. TEI’s 2026 Midyear Conference, held at the Grand Hyatt Washington…
TEI Debuts New Tax Lab at Midyear Conference At this year’s Midyear Conference, TEI introduced the Tax Lab,…
Introducing the 2026 Tax Leadership Academy Class We are pleased to announce the participants selected for the…