On March 31, 2024, TEI submitted comments to the Internal Revenue Service (the "Service") regarding foreign tax redeterminations ("FTRs") under section 905(c). The post-TCJA final regulations…
On March 29, 2024, TEI provided a submission to the British Columbia ("BC") Minister of Finance in response to the 2024 BC provincial budget and accompanying bill that introduce changes to the…
On March 15, 2024, TEI submitted comments on the new GST/HST joint venture ("JV") election rules to the Department of Finance in response to a request for comments in the November 21, 2023, Fall…
On March 15, 2024, TEI submitted comments to the United Nations regarding its Terms of Reference for a United Nations Framework Convention on International Tax Cooperation. TEI's comments focused on…
On March 5, 2024, TEI filed comments with the Australian Treasury regarding the Australian government's revised Exposure Draft proposing to require certain multinational corporations with operations…
On March 1, 2024, TEI filed comments with the Australian Taxation Office regarding its new interpretation of the characterization of payments made for software and other intellectual property. TEI's…
On February 12, 2024, TEI submitted comments regarding REG-132422-17 addressing recognition and deferral of section 987 gain or loss. TEI's comments included several simplifying recommendations to…
On February 9, 2024, TEI submitted comments to the Internal Revenue Service and U.S. Department of the Treasury regarding Notice 2023-80 (the "Notice"). The Notice provides interim guidance…
On January 22, 2024, TEI submitted to the European Commission regarding the Commission's proposed directive on Business in Europe: Framework for Income Taxation ("BEFIT"), which aims to simplify…
On January 3, 2024, TEI submitted a comment letter to the European Commission regarding its proposal for a transfer pricing directive. TEI's comments focused on the need to coordinate certain of the…
On December 23, 2023, TEI provided a submission to the British Columbia ("BC") Minister of Finance as part of the 2023 Consultation on the Provincial Sales Tax Application to Partnerships. TEI's…
On November 24, 2023, TEI submitted comments in response to a request for comments in Notice 2023-63 regarding section 174. TEI's comments included concerns over scope, cost allocation methods,…