Comment Letters

On February 5, 2019, TEI submitted responsive comments and recommendations to the Internal Revenue Service concerning the new proposed regulations under sections 861 and 904 of the Code (REG-105600-18). TEI’s comments, which are reprinted below, were developed by a cross-industry working group of Tax Reform Task Force and U.S. International Tax Committee members under the stewardship of TEI lawyers Watson M. McLeish and Benjamin R. Shreck.

On November 29th, TEI submitted comments to the Australian Treasury regarding its Discussion Paper on the digital economy and Australia’s corporate tax system.

On November 26th, TEI submitted comments to the Treasury and IRS regarding proposed regulations providing guidance under section 951A regarding global intangible low-taxed income.

In October 2018, TEI worked with the Council on State Taxation (COST) and AICPA to request that states issue guidance indicating they will waive late filing (but not late payment) penalties for state corporate tax returns due October 15 but filed by November 15, 2018.

On October 9, 2018, TEI submitted responsive comments and recommendations to the Internal Revenue Service concerning the new proposed regulations under section 168(k) of the Code, which was amended by Public Law 115-97 on December 22, 2017. TEI’s comments, which are reprinted below, were developed by a cross-industry working group of Federal Tax Committee and Tax Reform Task Force members under the leadership of Colleen C. Brown, Julia Lagun, and John P. Orr Jr. Watson M. McLeish, Tax Counsel for the Institute, coordinated the preparation of TEI’s comments.

On October 9th, TEI submitted comments to the Treasury and IRS regarding proposed regulations promulgated under the transition tax imposed by section 965, as amended by the Tax Cuts & Jobs Act enacted in 2017.

On September 20 and 24, 2018, TEI filed submissions responding to the European Commission’s Public Consultation regarding the evaluation of invoicing rulesTEI’s comments were prepared under the aegis of TEI’s European Indirect Tax Committee.

On September 14, 2018, TEI filed a letter with the British Columbia's Ministry of Finance proposing changes to British Columbia's provincial sales tax.

On September 28, 2019, TEI filed comments responding to the Department of Finance Canada’s Consultation Concerning the GST/HST Holding Corporation Rules, which solicits feedback on the Legislative and Regulatory Proposals Relating to the Excise Tax Act, the Excise Act, 2001 and the Air Travelers Security Charge Act.

On September 6th, TEI submitted comments to the OECD regarding its public discussion draft under BEPS Actions 8-10 on the transfer pricing aspects of financial transactions.