Submissions

On September 5th, 2025, TEI submitted comments to the Canada Revenue Agency regarding compliance with the Canadian excess interest and financing expense limitation ("EIFEL") regime. TEI's comments highlighted the unnecessary compliance costs imposed by the EIFEL reporting forms and made several recommendations about forms that could be eliminated or significantly modified. TEI's comments were prepared under the aegis of its Canadian Income Tax Committee, whose Chair is Sandy Shanks. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.

On September 12, 2025, TEI submitted comments to the British Columbia (BC) government recommending that BC replace the Provincial Sales Tax (PST) with the Harmonized Sales Tax (HST). TEI's letter was prepared under the aegis of its Canadian Commodity Tax Committee, whose Chair is Martin Behagg.

Read the comments here

On August 28, 2025, TEI submitted comments to the Canadian Department of Finance regarding Canada's 2025 pre-budget consultation along with TEI's ideas for Canadian tax reform. TEI's letter was prepared under the aegis of its Canadian Income Tax Committee, whose Chair is Sandy Shanks. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.

Read the comments here

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

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.

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.

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.

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.

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.

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.