Beginning on Monday, April 25, TEI’s Education Fund will sponsor its 2022 Federal Tax Course – Level 1 at the Kellogg Hotel & Conference Center on the grounds of Michigan State University in East Lansing, Michigan. The course, which is designed for individuals with less than five years’ experience in federal income tax matters, will feature a best-in-class faculty and unparalleled networking opportunities.
On October 31, 2023, TEI submitted comments on the proposed changes to Form 6765, Credit for Increasing Research Activities. TEI's comments included both general comments and comments on specific lines. The general comments focused on concerns over the unreasonable workload and burden imposed by the proposed changes.
On October 12, 2023, TEI submitted comments in response to a request for comments in Notice 2023-64 regarding the Corporate Alternative Minimum Tax. TEI's comments included recommendations for the AFSI calculation with regard to marked-to-market gains and losses, the potential duplication of income with respect to CFCs, depreciation method changes, and foreign parented entities.
On November 24, 2023, TEI submitted comments in response to a request for comments in Notice 2023-63 regarding section 174. TEI's comments included concerns over scope, cost allocation methods, software development definitions, the parties required to capitalize costs when research is performed under contract, and the treatment of costs incurred pursuant to long-term contracts.
On August 14, 2023, TEI submitted comments in response to a request for comments in proposed regulations under section 6418 regarding the transferability of certain credits to unrelated taxpayers.
On August 14, 2023, TEI submitted comments in response to a request for comments in proposed and temporary regulations under section 6417 regarding elective payments for certain credits. TEI's comments included concerns over burdensome pre-filing registration requirements and over limitations on the taxpayers able to make elective payment elections, namely partners in partnerships and shareholders in S corporations.
On March 20, 2023, TEI submitted comments in response to a request for comments in Notice 2023-2, which provided guidance on the stock repurchase excise tax. The comments requested carve-outs from the tax for redemptions of non-participating, non-convertible preferred stock and addressed the funding rule and related per se rule that were introduced in the notice. In particular, the comments requested either the removal of the rules from future guidance or a significant narrowing of the rules as they are overbroad and go beyond the literal language and purposes of the statute.
On March 20, 2023, TEI submitted a letter to the Internal Revenue Service commenting on Notice 2023-7, which provides initial guidance on the new corporate alternative minimum tax (CAMT) imposed by the Inflation Reduction Act of 2022. TEI's comments included the need for transition rules and penalty relief, adjustments to the determination of adjusted financial statement income (aka AFSI), among other things. TEI's comments were prepared under the aegis of the Institute's Tax Reform Task Force, whose Chair is Jason Weinstein.
On November 30, 2022, TEI submitted written comments to the U.S. Department of the Treasury and Internal Revenue Service requesting guidance on changes to section 174 under the Tax Cuts and Jobs Act of 2017, effective for tax years beginning after December 31, 2021. TEI’s comments were developed by members of several TEI standing committees under the aegis of TEI’s Federal Tax Committee, whose chair is Julia Lagun, and the effort was led by Betty Mak, a vice chair of the committee.