TEI Submits Additional Comments on CAMT Proposed Regulations
On July 25, 2025, TEI submitted additional comments on the proposed regulations for the corporate alternative minimum tax ("CAMT"). The Tax Reform Task Force, whose chair is Andreia Verissimo, in coordination with TEI Tax Counsel Kelly Madigan, spearheaded the comments. The letter reiterated several of TEI's prior comments on CAMT and included a new recommendation for an adjustment to AFSI for stock-based compensation.
Read the comments here
Canadian 2025-26 Pre-Budget Finance Committee Consultation - TEI Comments
On July 31, 2025, TEI submitted recommendations to the Canadian House of Commons' Standing Committee on Finance regarding its pre-Budget consultations for the 2025-26 fiscal year. TEI recommended the Canadian government conduct a comprehensive review of (i) the tax compliance burden faced by Canadian taxpayers; (ii) the income tax audit process, from the start of the audit itself through to the appeals and dispute resolution process; and (iii) the overly complex and burdensome foreign affiliate taxing and reporting regime.
Proposed Instructions to Form 6765- TEI Comments
On June 27, 2025, TEI submitted comments on the proposed instructions to Form 6765, Credit for Increasing Research Activities. The Tax Reform Task Force, whose chair is Andreia Verissimo, in coordination with TEI Tax Counsel Kelly Madigan, spearheaded the comments. TEI’s comments request guidance for taxpayers' using statistical sampling and reiterate concerns previously expressed by TEI on draft Form 6765. TEI submitted comments on draft Form 6765 on October 31, 2023.
Proposed Section 899's Impact on Canadian Companies - TEI Comments
On June 6, 2025, TEI submitted comments to the Canadian Prime Minister and Minister of Finance regarding proposed new Code section 899 of the One Big Beautiful Bill Act. Section 899 would impose retaliatory U.S. taxes on companies and individuals from countries that impose certain "unfair" taxes on U.S. companies and individuals, such as a digital services tax or UTPR. TEI's comments focused on the negative impact section 899 would have on Canadian companies should it be enacted into law.
TEI Submits Comments on UK Consultation for Digital Reporting and E-Invoicing
On May 1 2025, TEI’s EMEA Indirect Tax and Customs Committee submitted a letter in response to HM Treasury’s public consultation on real-time digital reporting and electronic invoicing. The letter expressed support for efforts to digitalize and automate tax administration, including the adoption of e-invoicing.
New Proposed Section 987 Regulations - TEI Comments
On March 11, 2025, TEI filed comments with the IRS and U.S. Department of the Treasury regarding proposed regulations under section 987, which were published on December 11, 2024. TEI's comments included recommending additional transactions be included in the recurring transfer group election under the proposed regulations, making the election available when companies use net value computations, and exempting CFCs from application of section 987(3). TEI's comments were prepared under the aegis of its U.S. International Tax Committee and Tax Reform Tas Force.
OECD GIR XML Users' Guide - TEI Comments
On March 20, 2025, TEI submitted comments to an Expert-Sub Group of OECD Working Party 10 regarding the Working Party's GloBE Information Return XML Schema and User Guide, which was published on January 15, 2025. TEI's comments focused on the need for the OECD to provide more information about, and examples illustrating, the XML Schema and its validation rules. TEI's EMEA Direct Tax Committee led preparation of the comments. Benjamin Shreck, TEI Tax Counsel, coordinated the comment drafting process.
Proposed PTEP Regulations - TEI Comments
On March 2, 2025, TEI submitted comments regarding the long-awaited proposed previously taxed earnings and profits ("PTEP") regulations. TEI's comments focused on the need to eliminate double taxation of PTEP by recommending a change to the proposed regulations' "share-by-share" approach to section 961 basis increases. TEI recommended that section 961 basis increases should be allocated pro-rata across all a U.S. shareholder's shares in a controlled foreign corporation. TEI's comments were prepared by members of its U.S. International Tax Committee and Tax Reform Task Force. Benjamin R.
Canadian Capital Gains Tax Increase - TEI Comments
On January 20, 2025, TEI submitted comments with the Canada Revenue Agency (CRA) regarding their administration of a potential increase in the Canadian capital gains inclusion rate. TEI noted the inappropriateness of CRA administering the increase as if it has been enacted into law when it has not, as well as the complications and financial burdens imposed on taxpayers. TEI's comments were prepared under the aegis of its Canadian Income Tax Committee. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.
The BC Minister of Finance Responds to TEI's Submission on the Definition of Software for the PST
TEI received a letter from the British Columbia Minister of Finance in response to the Canadian Commodity Tax Committee's March 29, 2024, submission. The Committee had submitted a letter addressing the 2024 British Columbia Budget changes to the Provincial Sales Tax ("PST") definition of “software,” including the retroactive impact of the changes and the expansion of the definition.