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The One Big Beautiful Bill Act
Assessing the impact of new tax legislation on single-family offices and their stakeholders
In July 4, President Donald Trump signed into law the One Big Beautiful Bill Act (OBBBA), marking the most comprehensive overhaul of US tax policy since the 2017 Tax Cuts and Jobs Act (TCJA). This landmark legislation brings significant changes with direct implications for single-family offices, high-net-worth investors, and closely… Read more »
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
Authors’ note. This article was prepared on April 22, updated on July 15, and is accurate as of that date. Please refer to legal counsel for up-to-date information on the status of the trade and tariff measures between Canada and the United States. Since his inauguration in January, US President… 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 »
Are Tax Insurance Proceeds Taxable? Tax insurance has emerged as a cornerstone of corporate tax…
OBBBA Modifications to US Taxation of International Income The One Big Beautiful Bill Act (OBBBA), which was signed…
How Does Conformity Impact State Revenues After the OBBBA? State conformity with the Internal Revenue Code (IRC) refers to…
Are Research Credit Interviews and Write-Ups Obsolete? Upon joining a Big Four firm in Washington, D.C.—then known…
Janelle Gabbianelli According to Janelle Gabbianelli, her first job was the catalyst…
Why Co-Sourcing Tax Technology Is Your Best Bet In today’s complex regulatory landscape, tax departments are being pushed…