Federal Tax

The Federal Income Tax Committee is responsible for TEI’s educational and advocacy efforts for U.S. federal income tax matters.

Register Now – TEI's Federal Tax Course – Level 1

2022 Federal Tax Course Banner

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.

FEDERAL TAX

Staff Liaison:

Kelly Madigan, Tax Counsel
202.464.8351

 


The Federal Income Tax Committee is responsible for TEI’s educational and advocacy efforts for U.S. federal income tax matters.

 

 

TEI Submits Comments on Stock Repurchase Excise Tax Proposed Regulations

On June 11, 2024, TEI submitted comments on the proposed regulations on the stock repurchase excise tax. TEI requested clarification on the method for electing to apply the proposed regulations retroactively to issuances and repurchases that occurred after December 31, 2022, but before the publication of the proposed regulations.

TEI Submits Comments on Form 6765, Credit for Increasing Research Activities

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.

Read the comments here.

TEI Submits Comments on Notice 2023-64 and CAMT

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.

Read the comments here.

TEI Submits Comments on Notice 2023-63 and Section 174

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.

Read the comments here.

 

TEI Comments on Proposed Regulations on the Transferability of Certain Credits

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.

TEI Comments on Proposed and Temporary Regulations on Elective Payments for Certain Credits

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.

Read the comments here.

TEI Submits Comments on Notice 2023-2 and the Stock Repurchase Excise Tax

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.

TEI Comments on IRS Notice 2023-7 Regarding the New Corporate AMT

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.

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