Submissions

TEI Submits Comments on Proposed Changes to Schedule UTP

On November 17, 2022, TEI submitted comments to the IRS on proposed changes to Schedule UTP. The comments identified a variety of critical policy issues that must be evaluated in a thoughtful and deliberative manner and urged the IRS to put an indefinite hold on the proposed changes and engage in a meaningful collaboration with stakeholders to identify reasonable alternatives.

Download the letter.

TEI Participates in Canadian Income Tax Mandatory Disclosure Rules Consultation

On April 5, 2022, TEI submitted written comments to the Department of Finance concerning the government’s newly released draft legislative proposals to amend Canada’s income tax mandatory disclosure rules.  These proposals were initially described in the federal budget documents tabled in Canada’s House of Commons on April 19, 2021 (“Budget 2021”), on which TEI provided preliminary feedback last fall.  Consistent with our e

TEI Participates in Consultation on Canada’s Proposed Excessive Interest and Financing Expenses Limitation

On May 6, 2022, TEI submitted written comments to the Department of Finance concerning the government’s newly released draft legislative proposals to limit the amount of interest and other financing expenses that businesses may deduct for Canadian income tax purposes.  These proposals were initially described in the federal budget documents tabled in Canada’s House of Commons on April 19, 2021 (“Budget 2021”), on which TEI provi

TEI Comments on the Proposed Implementation of Pillar Two (Global Minimum Tax) in Canada

On July 21, 2022, TEI submitted preliminary comments to the Department of Finance concerning the Government of Canada’s proposal to implement Pillar Two of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (“BEPS”) two-pillar plan for international tax reform, as contemplated by the federal budget documents tabled in Canada’s House of Commons on April 7, 2022 (“Budget 2022”).  TEI’s comments highlight several

TEI Applies for Leave to Intervene (as Amicus Curiae) in Deans Knight Income Corporation v. The Queen

On June 30, 2022, TEI applied for leave to intervene (as amicus curiae) in Deans Knight Income Corporation v.

TEI Submits Comments on the IRA’s Corporate Alternative Minimum Tax

On October 18, 2022, TEI submitted written comments to the U.S.

TEI Submits Comments on the IRS Form Being Developed to Standardize Rev. Proc. 94-69 Disclosures

On June 1, 2022, TEI submitted comments on draft IRS Form 15307, which the IRS is developing to standardize the process for making Rev. Proc. 94-69 disclosures so eligible taxpayers and revenue agents will have consistent guidelines around what constitutes adequate disclosure. TEI’s comments expressed fundamental concerns surrounding the proposed consequences of a deemed failure to provide adequate disclosures and provided a number of detailed suggestions intended to eliminate confusion and uncertainty when describing adjustments in the form.

TEI Submits Comments in the Public Consultation on VAT in the Digital Age

On May 30, 2022, TEI submitted formal comments in connection with the European Commission’s public consultation on VAT in the Digital Age.  The submission highlights the vastly different technological approaches Member States have taken to VAT reporting and recommends a unified digital approach.

Download the comments

TEI Comments on Proposed Interest Deductibility Limits in Canadian Budget 2021

On December 29, 2021, TEI submitted comments to the Department of Finance Canada concerning the government’s proposal to introduce a new limitation on the deduction of business interest expense, as described in Budget 2021.  Generally speaking, the proposal would limit the amount of net interest expense that a corporation could deduct in computing its taxable income to a fixed share of the corporation’s earnings.

TEI Supports Deans Knight Income Corporation's Application for Leave to Appeal

On October 1, 2021, TEI issued a letter in support of the taxpayer’s application for leave to appeal to the Supreme Court of Canada in Deans Knight Income Corporation v. Her Majesty the Queen.
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