On August 14, TEI responded to a request for comments concerning proposed regulations under Section 6418 regarding the transferability of certain credits to unrelated taxpayers. TEI’s comments included concerns about burdensome registration and election requirements and about provisions that substantially limit the taxpayers’ ability to take advantage of the credit transfer regime, as well as requests for clarification on he reasonable cause exception for excessive credit transfers, on a potential trap for the unwary regarding the “paid in cash” requirement, and on a filing issue for taxpayers with a 52/53 week year-end, plus a request for additional guidance on audit procedures and enforcement mechanisms.
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…
Masha Freyvert When Masha Freyvert was an undergraduate at Boston University, she…
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,…