Federal Tax

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 the Capitalization of R&E Expenditures under Section 174

On December 9, 2022, TEI submitted written comments to Congress regarding the changes to section 174 under the Tax Cuts and Jobs Act of 2017. The comments urged Congress to act before the end of the 2022 calendar year to postpone, if not repeal, the mandatory capitalization of expenditures under section 174. 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.

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 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 Comments on the Build Back Better Act’s Corporate and International Tax Reform Proposals

On December 9, 2021, TEI issued a compilation of substantive comments and recommendations concerning select corporate and international tax reform provisions in H.R. 5376, the Build Back Better Act, as passed by the House of Representatives on November 19, 2021. This submission represents the culmination of several months’ worth of consultation with members of TEI's Tax Reform Task Force and other standing committees, who contributed an array of perspectives and concerns from across the industry spectrum.

TEI Issues Guideposts for Tax Policy in the 117th Congress

On May 11, 2021, TEI officially weighed into the brewing tax reform debate in Washington, D.C., through the issuance of its new Guideposts for Tax Policy. The guideposts are intended to highlight a series of high-priority, broadly applicable principles of sound tax policy to inform the current deliberations in the 117th Congress and Biden administration. They are also intended to lay a solid, principles-based foundation to support TEI’s substantive, issue-focused advocacy activities in the weeks and months ahead. TEI encourages policymakers to adopt these guideposts

TEI Submits Comments to the IRS Concerning the Proposed Elimination of Revenue Procedure 94-69

On October 16, 2020, TEI submitted comments to the Large Business & International Division of the IRS urging the division to retain Rev. Proc. 94-69 and extend it to all taxpayers subject to the Large Coordinated Case Program.

TEI Holds 2020 Liaison Meetings with the Internal Revenue Service and U.S. Department of the Treasury

On February 27–28, 2020, a delegation of Executive Committee members, standing committee leaders, and Institute staff assembled in Washington, D.C., for TEI’s annual liaison meetings with the Internal Revenue Service and U.S. Department of the Treasury.

TEI Holds U.S. Congressional Liaison Meetings

On May 1–2, 2019, a delegation of Executive Committee and Tax Reform Task Force members assembled in Washington, D.C., for the Institute’s first set of congressional liaison meetings since the late 1990s.

TEI Participates in Annual IRS and Treasury Department Liaison Meetings

On February 28 and March 1, 2019, TEI participated in its annual liaison meetings with senior officials from the IRS and Treasury’s Office of Tax Policy.

TEI Comments on Proposed Section 163(j) Regulations

On February 26, 2019, TEI submitted responsive comments and recommendations to the Internal Revenue Service concerning the proposed regulations under section 163(j) of the Internal Revenue Code (REG-106089-18). TEI’s comments, which are reprinted below, were developed by a cross-industry working group of Tax Reform Task Force and Federal Tax Committee members under the stewardship of Watson M. McLeish, tax counsel for the Institute.