Institute News
TEI Submits Comments on Notice 2023-2 and the Stock Repurchase Excise Tax
On March 20, TEI submitted comments in response to a request for comments in Notice 2023-2, which provided guidance on the stock repurchase excise tax. The comments requested carve-outs from the tax for redemptions of nonparticipating, nonconvertible preferred stock and addressed the funding rule and related per se rule that… Read more »
TEI Comments on OECD Consultation on Pillar One, Amount B
On January 25, TEI submitted comments to the Organisation for Economic Co-operation and Development (OECD) regarding the OECD’s public consultation on the design elements of Pillar One, Amount B. TEI’s comments included the need to broaden the scope of Amount B to achieve its goal of transfer pricing simplification, ensure… Read more »
TEI Submits Comments on Proposed Changes to Schedule UTP
On November 17, TEI submitted comments to the Internal Revenue Service on proposed changes to Schedule UTP. The comments identified various critical policy issues that must be evaluated in a thoughtful and deliberative manner and urged the IRS to put an indefinite hold on the proposed changes and engage in… Read more »
TEI Submits Comments on the Capitalization of R&E Expenditures Under Section 174
On December 9, TEI submitted written comments to Congress regarding the changes to Section 174 under the Tax Cuts and Jobs Act of 2017. The comments urged Congress to act before the end of the 2022 calendar year to postpone, if not repeal, the mandatory capitalization of expenditures under Section… Read more »
TEI Comments on OECD Pillar Two GloBE Information Return Consultation
On February 3, TEI submitted comments to the Organisation for Economic Co-operation and Development (OECD) regarding the GloBE Information Return under Pillar Two of the OECD’s project on the digitization of the economy. The Institute’s comments primarily focused on ways to reduce the volume of information required under the return,… Read more »
Lynn Spence Promoted to Director, Information Technology & Web Services
TEI staff member Lynn Spence was promoted to director, information technology and web services in March. Spence joined TEI in February 2020 and has played an instrumental role with TEI through and after the pandemic, including moving TEI’s systems to the cloud, training staff and members on TEI resources, assisting… Read more »
TEI Submits Comments on Draft Form RC312 Under Canada’s Mandatory Disclosure Rules
On February 13, TEI filed comments with the Canada Revenue Agency regarding Draft Form RC312 – Reportable Transaction and Notifiable Transaction Information Return. TEI’s comments primarily concerned the volume of information required by the form as well as the unclear nature of several provisions on the form. TEI’s comments were… Read more »
TEI Submits Comments on Proposed Canadian EIFEL Rules
On January 31, TEI filed comments and recommendations with the Canadian Department of Finance regarding proposed excessive interest and financing expense limitation (EIFEL) legislation. The Institute’s recommendations included delaying the effective date of the rules, providing transition relief, and not applying the EIFEL rules when computing the foreign accrual property… Read more »
TEI Requests Guidance on the Capitalization of R&E Expenditures Under Section 174
On November 30, TEI submitted written comments to the US Department of the Treasury and the Internal Revenue Service requesting guidance on changes to Section 174 under the Tax Cuts and Jobs Act of 2017, effective for tax years beginning after December 31, 2021. TEI’s comments were developed by members… Read more »
TEI Comments on OECD Pillar Two GloBE Tax Certainty Consultation
On February 3, TEI provided comments to the Organisation for Economic Co-operation and Development (OECD) regarding its public consultation on GloBE tax certainty under the OECD’s two-pillar approach to the tax consequences of the digitization of the economy. The Institute’s comments focused on preventing and resolving tax disputes arising from… 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 Price of Regulatory Certainty Prior to the Inflation Reduction Act (IRA) of 2022, transferability…
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,…
Masha Freyvert When Masha Freyvert was an undergraduate at Boston University, she…