U.S. INTERNATIONAL

The U.S. International Tax Committee works on educational and advocacy efforts regarding the U.S. taxation of international business operations.

On October 9, 2018, TEI filed comments with the United States Department of the Treasury and Internal Revenue Service regarding proposed regulations issued under section 965. Section 965, as amended…
On September 1, 2017, TEI submitted further comments to the Internal Revenue Service on the final debt documentation requirements in Treas. Reg. § 1.385-2 (T.D. 9790, 81 Fed. Reg. 72,858).  Our…
On August 7, 2017, TEI submitted comments to the Internal Revenue Service on the final and temporary regulations under section 385 (T.D. 9790, 81 Fed. Reg. 72,858) concerning the treatment of certain…
On March 7, 2017, TEI filed comments with the IRS regarding final, proposed, and temporary regulations addressing the recognition foreign currency gain of qualified business units under section 987…
On January 12, 2017, TEI Executive Director Eli Dicker and Tax Counsel Benjamin Shreck participated in a roundtable discussion of the IRS’s administration of country-by-country (CbC) reporting.  The…
On October 11-12, 2016, TEI Tax Counsel Ben Shreck participated in the OECD’s Public Consultations regarding revised OECD guidance on the use of the profit split method for transfer pricing purposes…
On September 30, 2016, the European Commission reappointed TEI as a member of the VAT Expert Group for a three-year term. The VAT Expert Group was established in 2012 for the purpose of “advis[ing]…
On July 6, 2016, TEI submitted comments to the Internal Revenue Service regarding its proposed regulations for 26 U.S.C. § 385, which would give the IRS broad authority to recharacterize related-…
On March 21, 2016, TEI submitted comments to the IRS regarding proposed regulations (REG-109822-15) that would require certain U.S. headquartered multinational enterprises to report financial and tax…
On March 10, 2014, TEI submitted comments to the IRS regarding Notice 2013-78, which proposes substantial revisions to Revenue Procedure 2006-54 for requesting assistance from the U.S. competent…
On March 10, 2014, TEI submitted comments to the IRS regarding Notice 2013-79, which proposes substantial revisions to Revenue Procedure 2006-9 for requesting advanced pricing agreements (APA) from…
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