Proposed Instructions to Form 6765- TEI Comments
On June 27, 2025, TEI submitted comments on the proposed instructions to Form 6765, Credit for Increasing Research Activities. The Tax Reform Task Force, whose chair is Andreia Verissimo, in coordination with TEI Tax Counsel Kelly Madigan, spearheaded the comments. TEI’s comments request guidance for taxpayers' using statistical sampling and reiterate concerns previously expressed by TEI on draft Form 6765. TEI submitted comments on draft Form 6765 on October 31, 2023.
TEI Submits Supplemental Comments on Notice 2023-63, Section 174, and Software Development
On October 2, 2024, TEI submitted supplemental comments on Notice 2023-63 and section 174, with a particular focus on rules related to software development for future proposed regulations. The comments address timing issues with respect to wage SREs, the appropriate nexus for indirect costs to be considered SREs, and a reasonable analytical framework under section 174. TEI also provided additional examples that would clarify which software-related costs need to be capitalized under section 174.
TEI Submits Comments on Notice 2023-63, Section 174, and Software Development
On July 24, 2024, TEI submitted comments on Notice 2023-63 and section 174, with a particular focus on rules related to software development for future proposed regulations. TEI requested rules for determining the proper unit of account with respect to SREs and further guidance on what does and does not constitute software development. TEI included numerous examples that would clarify which software-related costs need to be capitalized under section 174.
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.
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 to the IRS Concerning the Proposed Elimination of Revenue Procedure 94-69
TEI Holds 2020 Liaison Meetings with the Internal Revenue Service and U.S. Department of the Treasury
TEI Participates in Annual IRS and Treasury Department Liaison Meetings
TEI Members Participate in 2017 IRS and US Treasury Liaison Meetings
On February 22-23, 2017, a delegation from Tax Executives Institute met with the Commissioner of Internal Revenue, John Koskinen, and senior officials of the Internal Revenue Service and with the Treasury Department’s Tax Legislative Counsel, Tom West, and senior officials of Treasury’s Office of Tax Policy. The detailed agendas TEI submitted to the IRS and Treasury Department before the meetings are provided below.