Submissions

On November 10, 2025, TEI submitted comments on the implementation of a number of the provisions in the One Big Beautiful Bill Act (OBBBA). The Tax Reform Task Force, whose chair is Andreia Verissimo, in coordination with TEI Tax Counsel Kelly Madigan, prepared the comments. The comments focused on the interaction between the Corporate Alternative Minimum Tax (CAMT) and section 174A, including a detailed discussion of the statutory grant of rulemaking authority in sections 56A(c)(15) and 56A(e) and the purposes of the CAMT.

On October 20, 2025, TEI submitted comments on Notice 2025-44, which announced the forthcoming withdrawal of final regulations regarding disregarded payments losses and related changes to the dual consolidated loss (DCL) rules, among other things. The Tax Reform Task Force, whose chair is Andreia Verissimo, in coordination with TEI Tax Counsel Kelly Madigan, prepared the comments.

On September 12, 2025, TEI submitted comments to the Canadian Department of Finance regarding proposed legislation that would enhance the Canada Revenue Agency's audit powers. TEI's commented on the difficulties taxpayers would have in handling CRA requests under the new audit powers, the unfairness of newly proposed penalties in many circumstances, and how the proposed audit process under the new proposals is unclear. TEI's letter was prepared under the aegis of its Canadian Income Tax Committee, whose Chair is Sandy Shanks. Benjamin R.

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.