On October 6, TEI submitted comments to the Inland Revenue Authority of Singapore in response to an invitation for public comment on proposed rules governing transfer pricing documentation.
On September 26, TEI submitted recommendations to the Canadian Department of Finance urging revisions to draft legislation released August 29, 2014, that restrict back-to-back loans through intermediaries.
On September 26, TEI filed an amicus brief with the U.S. Supreme Court in a case involving the constitutional limitations on a state’s ability to tax business income earned outside the borders of that state.
On September 19, TEI submitted comments on proposed changes to the GST/HST nil consideration election under section 156 of the Excise Tax Act.
On September 17, TEI submitted recommendations to the OECD on BEPS Action 11 regarding methodologies to collect and analyze data on base erosion and profit shifting.
On August 26, TEI submitted a number of proposed changes to the British Columbia Provincial Sales Tax Act that would streamline administration and address policy issues.
On July 18, TEI submitted comments on proposed changes to Canadian GST/HST section 273 joint venture elections.
On August 1, 2014, TEI completed its first project of direct tax advocacy with China’s State Administration of Taxation (SAT), when it filed comments regarding draft administrative measures on the Chinese domestic law General Anti-Avoidance Rule (GAAR).
On August 6, 2014, Tax Executives Institute submitted a written statement to the House of Commons Standing Committee on Finance in connection with the 2014 pre-budget consultations in Canada.
On July 21, TEI submitted comments regarding the Irish government’s public consultation on the OECD’s base erosion and profit shifting project.
On July 14, TEI filed comments with the South African Revenue Service on new VAT rules affecting foreign-based supplies of electronic services.
On June 27, TEI submitted comments to the Canadian Department of Finance on the collection of GST/HST on e-commerce sales.
On June 11, 2014, Tax Executives Institute submitted comments on the Consultation on Tax Planning by Multinational Enterprises announced in Annex 2 of the 2014 Canadian Budget Message.
On June 5, TEI submitted recommendations to the European Commission on areas of VAT place of supply guidance for services connected with immovable property.
On May 5, TEI submitted comments to the IRS regarding regulations implementing FATCA and coordinating regulations under Chapters 3, 4 and 61 of the Code.
On May 1, TEI submitted comments to the OECD regarding its recommendations for domestic law and discussion of treaty issues that the OECD believes are necessary to address tax planning through hybrid mismatches.
On Apr. 13, TEI submitted comments to the OECD regarding its public discussion draft on potential options to address the tax challenges of the digital economy.
TEI urged Canada to revise substantially its treaty shopping proposals, substitute negotiated treaty LOB provisions for “main purpose” anti-abuse domestic legislation, and withdraw the back-to-back loan provision.
On Apr. 8, TEI submitted comments to the OECD regarding potential changes to its Model Tax Convention to prevent the inappropriate granting of treaty benefits.
TEI urges the IRS to withdraw proposed regulations on the treatment of intra-group gross receipts in the calculation of the section 41 research credit.
On Mar. 10, TEI submitted comments to the IRS regarding Notice 2013-79, which proposes substantial revisions to the revenue procedure for requesting advanced pricing agreements.
On Mar. 10, TEI submitted comments to the IRS regarding Notice 2013-78, which proposes substantial revisions to the revenue procedure for requesting assistance from the U.S. competent authority.
On March 7th, TEI submitted comments to the United Nations regarding the United Nations Practical Manual on Transfer Pricing for Developing Countries.
On March 6, TEI submitted a letter urging the creation of a critical tool that would greatly assist businesses with their VAT compliance efforts.
On Feb. 12, 2014, TEI submitted comments to the OECD recommending substantial changes to the OECD’s revisions to Chapter V of its Transfer Pricing Guidelines.
On Feb. 12, 2014, TEI filed a letter urging the British Columbia Ministry of Finance to address issues that would improve the administrability of the provincial sales tax (PST) system.
On Feb. 11, TEI submitted recommendations to Canada Revenue Agency for prioritizing “folio” guidance for Canadian taxpayers and tax advisers.
TEI submitted a letter in support of legislation in Alabama (SB 74) that would establish a pre-payment, independent tribunal to hear appeals of tax assessments and other matters administered by the Alabama Department of Revenue.
TEI urges the Department of Finance to refrain from adopting vague anti-abuse domestic legislation to curb treaty shopping. If legislation is adopted, TEI recommends inclusion of relieving provisions, exceptions, and administrative review procedures.
Check here for the agendas and updates from the Dec. 3-4, 2013, Canadian Liaison meetings.
On November 13, 2013, Tax Executives Institute filed comments with the IRS and Treasury Department urging a number of changes to the proposed regulations under sections 6055 and 6056.
As you may have recently read in the tax press or heard about at TEI’s Annual Conference, LB&I has redesigned its examination process to increase the efficiency, effectiveness, and transparency of its audits.
On October 16th, the Institute filed additional comments with the OECD regarding its base erosion and profit shifting (BEPS) Action Plan.
On September 18, TEI submitted comments to the OECD regarding its Base Erosion and Profit Shifting Action Plan.
TEI's recent comments on the OECD's White Paper on Transfer Pricing Documentation focused on the need to reduce the transfer pricing documentation and compliance burden on taxpayers by standardizing requests for such documentation across tax authorities.
On October 1, TEI submitted comments to the OECD regarding its Revised Discussion Draft on Transfer Pricing Aspects of Intangibles.
On September 16, TEI submitted recommendations to the European Commission on areas of VAT place of supply guidance for sales of telecommunications, broadcasting and electronic services.
On September 11, TEI submitted a letter to the OECD commenting on its Draft Handbook on Transfer Pricing Risk Assessment.
On August 26, TEI submitted a letter to the U.S. Department of the Treasury and Internal Revenue Service commenting on the final regulations under the Foreign Account Tax Compliance Act.
TEI submits Pre-Budget Consultation recommendations for Regulation 102/105 Withholding Waivers, Group Loss Transfers, and an Excise Tax Study and Consultation.