On March 18, 2014, TEI urged the IRS to withdraw proposed regulations creating an "exception" to the single taxpayer rule under section 41(f)(1) excluding gross receipts received from a controlled…
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…
On March 7, 2014, TEI submitted comments to the United Nations regarding the United Nations Practical Manual on Transfer Pricing for Developing Countries. TEI recommended, among other things, that…
On February 22, 2014, TEI submitted comments to the OECD recommending substantial changes to the OECD’s revisions to Chapter V of its Transfer Pricing Guidelines included in its Discussion Draft on…
On February 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, including…
On February 11, 2014, TEI submitted a letter to the Publications Section of Canada Revenue Agency making recommendations for prioritizing the development and publication of folio guidance for…
On January 17, 2014, TEI submitted a letter in support of Alabama legislation (SB 74) that would establish a pre-payment, independent tribunal to hear appeals of tax assessments and other matters…
On December 16, 2013, TEI submitted comments to the Department of Finance, Canada, in respect of its consultation on treaty shopping. The comments were prepared under the aegis of the Institute’s…
On December 3-4, 2013, representatives from TEI, led by 2013-2014 Vice President for Canadian Affairs Shiraz J. Nazerali, met with officials from Canada Revenue Agency and the Canadian Department of…
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. The proposed…
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…