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.
On February 26-27, a delegation of members led by TEI President Carita Twinem met with government officials for the annual liaison meetings. The minutes are now available.
On June 10, TEI submitted the following comments to the Financial Accounting Foundation (FAF) in connection with the FAF's post-implementation review of Financial Accounting Standards Board Statement No. 109, Accounting for Income Taxes (codified as
On June 10, TEI submitted comments to the Alabama Department of Revenue on its proposed local sales tax regulation governing seller collection responsibilities.
On May 10, TEI submitted a letter to the OECD commenting on recently released draft place of supply guidelines for cross-border sales of services and intangibles.
The responses of Canada Revenue Agency on excise tax matters from the December 3, 2012 liaison meeting are now available. Also available are the agendas and responses from the CRA on income tax matters.
On February 19 and 20, 2013, Tax Executives Institute submitted letters in support of legislation in Alabama (HB 264 and SB 223) that would establish a pre-payment, independent tax tribunal.
On March 29, 2013, TEI submitted a letter to the Manitoba Ministry of Finance urging the province to establish a statutory four-year limitation period for assessments of the Provincial Sales Tax.
On March 4, 2013, TEI filed a letter urging the British Columbia Ministry of Finance to formally adopt a policy of administrative tolerance for Provincial Sales Tax (PST) audits during the first year of the "new" tax.
On March 4, TEI submitted a memorandum to the MTC urging it to abandon a proposed project aimed at creating model regulations governing the use of state statutory authority to adjust income and expenses between related parties (i.e., transfer pricing).
IRS urged to refrain from creating exceptions to Rev. Proc. 2011-29; include accounting and legal fees in the procedure's safe harbor.
The Institute's letter refers to TEI's policy statement and encourages state legislators to enact tax tribunal statutes consistent with the ABA's Model Act.
The Institute's comments generally focused on three aspects of the Discussion Draft: (i) the meaning of "at the disposal of"; (ii) the time requirement for a PE; and (iii) the use of subcontractors.
The Institute says the 70-30 safe harbor for success-based fees should apply to the full amount of IB fees regardless of the timing of payments.
The Institute's letter focused on the administrative aspects of the PST Act containing comments designed to assist the Ministry of Finance with the practical, effective, and efficient administration of the new PST.
The Institute's letter noted the increasing frequency with which a number of EU Member States have refused to refund VAT to businesses that are in a repayment position and urged the Commission to take necessary actions against those Member States.
The Institute commended CRA for efforts and suggested a number of clarifications to the draft Technical Information Bulletin.
The Institute's brief urged the Supreme Court of the United States to reverse lower court decisions in Alabama holding that gain from the sale of property used in a taxpayer's unitary business constituted nonbusiness income allocable in full to Alabama.
TEI's letter praised the Government of India's Expert Report for recognizing that retrospective tax legislation should be enacted only in exceptional and rare cases.
TEI filed comments with the Canadian Department of Finance on a government consultation relating to the use of contingent fee arrangements in prosecuting claims for the Scientific Research & Experimental Development (SR&ED) tax incentives.
TEI's letter addressed the OECD's approach to safe harbours for setting transfer prices and urged the OECD to focus on an ex ante approach to transfer pricing timing issues.
TEI's letter praised the draft commentary but urged the OECD to make changes to the document that would strengthen the application of the VAT neutrality principle.
TEI's letter focused on the OECD's functional approach to return allocation from intangible assets for transfer pricing purposes.
The Institute's letter urges the Province to use proceeds from the tax to provide incentives for businesses that make investments in alternative fuel sources, methods for capturing emissions, or other "green" projects.
TEI urged the Canadian Department of Finance to revise the foreign affiliate dumping legislation released on August 14. TEI also questioned the cutbacks in the SR&ED tax incentives and the proposed withholding tax treatment of certain deemed dividends.
Canada's House of Commons kicked off its annual pre-budget consultations with a request from the Standing Committee on Finance that participants file responses to five standardized questions. TEI's responses to these questions are now available.
TEI's letter summarizes the Institute's general support for the HST and makes recommendations to enable the Province and taxpayers to achieve the benefits of reducing the complexity and costs of compliance with the new tax system.
In response to an invitation by the BC Expert Panel on Business Taxation, the Institute provided recommendations to make the province's tax system more competitive and to simplify its administration.
An anti-avoidance measure in the 2012 Canadian Budget is overbroad, TEI says, urging modifications to facilitate effective cash management and financing for foreign affiliates of non-resident parent companies.
TEI's letter, filed with the European Commission, expressed the Institute's general concerns regarding the EC's public consultation paper on instances of double non-taxation in the European Union's internal market.