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Protecting Privilege in ‘Work From Anywhere’ Era
The move toward remote or hybrid work arrangements is underway and irreversible
Even prior to the COVID-19 pandemic, tax functions were adapting and reacting to fundamental change and uncertainty. Whether the changes were brought about by the Tax Cuts and Jobs Act, by ever more aggressive positions taken by state and local auditors, by complex and burdensome reporting regimes, by novel taxes… Read more »
Presto Change-o: Unwinding Transactions in the Face of Uncertainty
It’s all about the rescission doctrine
With tax reform on the horizon, many companies are actively considering how the various proposals could impact their business and how they should structure their operations. However, many companies do not want to go all in and pull the trigger on a transaction based on what may amount to an… Read more »
The Changing Landscape of Indirect Tax
Guidance on emerging challenges in state and local indirect tax in the wake of COVID-19
The indirect tax landscape has changed rapidly in response to the COVID-19 pandemic. If the Supreme Court’s decision in South Dakota v. Wayfair in 2018 created a new playing field, complete with new marketplace facilitator guidance, the global pandemic has moved the goalposts. In this demanding environment, what is the… Read more »
Embracing the Certainty of Change
In challenging times, accept change and leverage opportunity
In a world where new laws and regulations seem to spring from nowhere, everything is subject to change. So, what should you do, TEI member? First, accept that uncertainty will be the norm with respect to domestic and international corporate tax policy. The congressional intent behind the laws that Treasury… Read more »
ESG Tax Transparency
You might want to check out BRT’s statement signed by 181 CEOs
In years gone by, business looked primarily to increasing shareholder returns, paying less attention to how their business practices affected the environment and society. For many, the primary concern in supply chain design was cost, with little inquiry into how supply chain partners conducted business. But more and more, such… Read more »
Jump-Starting Tax Automation, With Practical Tips to Sustain Momentum
Tax needs automation now more than ever—and fast
Tax functions have pursued automation and efficiency for a long time. Enterprise financial and management reporting systems are not designed to produce tax outputs such as tax provisions, tax returns, and other key tax deliverables, but instead provide the source financial data required to prepare the tax calculations—and that is… Read more »
Planning for People Within Your Technology Road Map
What path are you taking?
A road map lays out the path to get from where you are today to where you want to be in the future. In technology settings, the term is often used to conceptualize the work that needs to be completed for a technology solution to be ready for use. However,… Read more »
Who Is Interested in My Request for Interest?
Procedural missteps can risk taxpayers’ pursuit of overpayment interest from the IRS
The law is clear: “If a taxpayer overpays its taxes, the IRS owes the taxpayer interest on that amount.”1 This obligation certainly characterized the Internal Revenue Service’s 2020 fiscal year, in which the IRS paid more than $3 billion of overpayment interest to taxpayers.2 This figure is just the latest… Read more »
Let’s Make a Federal Case Out of It: Time to Revisit the Tax Injunction Act
There’s been no change in the TIA in more than 80 years—really
Most state taxpayers would prefer to litigate state and local tax cases in federal courts. However, disputes over state and local taxes are almost always decided by state courts. Although litigation in state court may seem natural and obvious to most state tax professionals, it is somewhat odd given the… Read more »
The Global Tax Information Age
International exchange of info growing—but still room for development
For years, governments around the world have called for changes to tax administration to prevent abusive tax avoidance and tax evasion. The need for change has been driven in part by the increasingly globalized economy, where cross-border activities and transactions are the norm rather than the exception. The Organisation for… Read more »


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TEI to Comment on New Proposed Section 987 Regulations The US Treasury Department and Internal Revenue Service published new…