HomePage
Nuts, Bolts, and Nuances of the Competent Authority Process
Relief is provided in most cases, but pitfalls and new issues are multiplying
The competent authority procedure is a dispute resolution mechanism available to taxpayers facing cross-border disputes under an applicable tax treaty. The taxpayer may invoke this procedure to require the tax administration’s competent authority function to “endeavor” to resolve the dispute by “mutual agreement” with its counterpart in the treaty partner… Read more »
Tax-Efficient Supply Chain in Shadow of Tax Reform
GILTI, FDII, and BEAT: they’re not just acronyms—they require reassessing tax consequences of existing supply chain structures
For the past quarter century the same legal framework and economic incentives have driven how multinational corporations structure their supply chains. Relatively high U.S. corporate rates incentivized companies to locate valuable assets and operations in lower-taxed jurisdictions; the United States’ worldwide tax regime incentivized retaining and reinvesting those earnings outside… Read more »
Anatomy of a Multijurisdictional Dispute
Recent tax reform presents additional considerations
Demands on tax executives have never been higher. Whereas international tax rules have always been complex, the Organisation for Economic Co-operation and Development’s Base Erosion and Profit Shifting (BEPS) Action Plan and now U.S. tax reform introduce new levels of complexity and uncertainty. At the same time, sensational media coverage… Read more »
TEI Interview: John Koskinen
Former IRS commissioner gives TEI members an up-close look at why budgetary constraints presented a major challenge during his tenure—and still do
John Koskinen served as IRS commissioner for almost four years before leaving office in November 2017. As IRS commissioner, Koskinen dealt with thorny issues, including antiquated technology, the growing importance of international tax issues, and, of course, budget constraints. Tax Executive was granted one of the first interviews with Koskinen… Read more »
Effective NOL Planning in Light of Tax Reform
Can your company unlock the value of net operating loss carryforwards to reduce future taxable income?
Under current tax rules, a corporation can generally carry back a net operating loss (NOL) to the two preceding taxable years and carry it forward up to the twenty taxable years following the loss to offset 100 percent of federal taxable income and ninety percent of the alternative taxable income.… Read more »
Pros and Cons of Voluntarily Disclosing Past Wrongs
To disclose or not to disclose, that is the question
Hamlet’s thoughts weighed heavily upon him. Should he suffer the slings and arrows of outrageous fortune, or take arms against a sea of troubles? For the young Prince of Denmark seeking to avenge his father’s death, the choice was action or inaction, and ultimately life or death. Fortunately, most tax… Read more »
TEI Roundtable No. 16: Diversity and Inclusion in the Tax Industry
A growing commitment to a policy with clear-cut business benefits
Workforce diversity is a concern in every industry, and tax is no exception. But what issues are currently relevant, and is there a business rationale for increasing diversity? To explore this topic further, Tax Executive convened a roundtable discussion group composed of diversity leaders in the industry, including Margie Dhunjishah,… Read more »
Section 199 and Cloud Software: Clearing the Fog
Are you up-to-date on current Treasury regs?
The domestic production activity deduction under Section 199 of the Internal Revenue Code of 1986, as amended (hereinafter “Section 199”), provides a deduction equal to nine percent of the lesser of taxable income or income attributable to certain qualified production activities. For the 2016 fiscal year, this deduction was estimated… Read more »
Addressing New Federal Partnership Audit Rules and Reporting of Federal Adjustments to States
Bipartisan Budget Act of 2015 provides opportunity for greater uniformity
In recent years Tax Executives Institute, Inc. (TEI), has met with various state organizations and revenue departments to encourage standardizing the rules for reporting federal audit adjustments. These efforts have been fruitful but have even greater potential for success with the passage of the Bipartisan Budget Act of 2015 (BBA),… Read more »
Practical Questions for Multinationals in an MLI World
MLI moves to implementation with open issues and challenges
Now that the multilateral instrument (MLI)1 coordinated by the Organisation for Economic Cooperation and Development (OECD) has been signed by over seventy jurisdictions,2 the new international tax agreement has moved to the implementation phase, with open issues and challenges ahead. The practical outgrowth of the OECD’s project to address base… Read more »
AI in the Tax Department: Getting Tax a Seat at the Table Artificial intelligence (AI) is reshaping business functions rapidly, yet many…
Planning for IRS Audits in an Era of Uncertainty In its ongoing crusade against so-called “basis-shifting” transactions, the Internal…
Transfer Pricing and Valuation in Financial Transactions Business transactions such as mergers, acquisitions, and reorganizations often necessitate…
TEI Roundtable No. 52: FASB Accounting Standards Update 2023-09—Income Taxes (Topic 740) As financial reporting evolves, the Financial Accounting Standards Board (FASB)…
TEI Roundtable No. 53: Using AI for Tax Law Research As artificial intelligence continues its scorching rise, in-house tax professionals…
Andreia Verissimo Andreia Verissimo, the senior manager for US tax policy at…