Institute News
TEI Files Comments on Canada’s Proposed Pillar Two Legislation
On September 29, TEI submitted comments to the Department of Finance Canada regarding its proposed legislation to implement Pillar Two of the Organisation for Economic Co-operation and Development’s project on the taxation of the digitization of the economy. Canada’s legislation, titled the Global Minimum Tax Act, encompasses most, but not… Read more »
TEI Files Comments on the GloBE Information Return
On October 6, TEI submitted comments to the Organisation for Economic Co-operation and Development (OECD) and the European Commission regarding the GloBE Information Return (GIR) under Pillar Two of the OECD’s two-pillar approach to the tax challenges arising from the digitization of the economy. TEI’s comments focused on the volume… Read more »
TEI Files Comments on Canada’s Excessive Interest and Financing Expenses Limitation Rules
On September 13, TEI submitted comments to the Department of Finance Canada regarding proposed legislation that would implement an excessive interest and financing expenses limitation (EIFEL). TEI’s comments addressed the proposed implementation date of the EIFEL rules, the need to except existing debt obligations from the rules for a period… Read more »
Pillar One—Amount B: TEI Comments to the OECD
On September 1, TEI submitted comments responding to the Organisation for Economic Co-operation and Development’s (OECD’s) public consultation document regarding Pillar One—Amount B. TEI recommended the OECD make Amount B an elective safe harbor for multinational enterprises, increase the scope of the definition of “distributor,” and enhance the mechanisms for… Read more »
TEI Comments on Canadian Draft RUTT Form
On June 7, TEI submitted comments to the Canada Revenue Agency (CRA) regarding the draft Reportable Uncertain Tax Treatment (RUTT) form. Taxpayers must use the RUTT form to report certain items depend-ing on how those items are treated on a taxpayer’s relevant financial statements. TEI’s comments focused on recommendations to… Read more »
TEI’s New Student Committee
We are pleased to announce that TEI’s board of directors has approved the addition of a Student Committee at the 2023 Annual Meeting of Members. This appointment recognizes the increasing importance of inspiring students to pursue careers in taxation and acknowledges the efforts of TEI’s student members to launch TEI’s… Read more »
TEI Holds Its Inaugural International Tax Student Case Competition
On August 19, TEI held its inaugural International Tax Student Case Competition in Montreal. Five teams of four students each from universities in North and South America competed to determine which team could devise the best solution to a set of international tax issues. The Case Competition was the brainchild… Read more »
TEI Comments on Proposed Revisions to Canadian APA Program
On July 21, the Institute filed comments with the Department of Finance Canada regarding Information Circular 94-4R2, International Transfer Pricing: Advance Pricing Arrangements. TEI’s comments included concern about the undue compliance burden the Circular proposes to impose on taxpayers, its unreasonable filing deadlines, and the additional requirements for renewing an… Read more »
Appointment of the 2023–2024 Executive Committee
Each year, TEI’s incoming international president selects an Executive Committee from the members of TEI’s board of directors to join the Institute’sfour officers in their oversight of the Institute’s business affairs. We are excited to announce the following appointments for the 2023–2024 fiscal year.
TEI Comments on Proposed and Temporary Regulations on Elective Payments for Certain Credits
On August 14, TEI responded to a request for comments on proposed and temporary regulations under Section 6417 regarding elective payments for certain credits. TEI’s comments included concerns over burdensome prefiling registration requirements and over limitations on the taxpayers able to make elective payment elections, namely partners in partnerships and… Read more »
New Group Pricing Structure One of my key goals for the 2025–2026 fiscal year…
Corporate Apportionment of Partnership Income A decision issued by the Virginia Court of Appeals, FJ…
2026 State Tax Changes According to the Tax Foundation, forty-three states made significant changes…
The Supreme Court Ruling and the Potential for Tariff Refunds: Their Impact on Transfer Pricing When the United States introduced reciprocal tariffs in April 2025,…
The Price of Regulatory Certainty Prior to the Inflation Reduction Act (IRA) of 2022, transferability…
Masha Freyvert When Masha Freyvert was an undergraduate at Boston University, she…