U.S. International Tax

The U.S. International Tax Committee works on educational and advocacy efforts regarding the U.S. taxation of international business operations.

U.S. INTERNATIONAL TAX

Staff Liaison:

Ben Shreck, Tax Counsel
202.464.8353

 


The U.S. International Tax Committee works on educational and advocacy efforts regarding the U.S. taxation of international business operations.

TEI Files Comments on OECD Pillar One and Pillar Two Blueprints

On December 13, TEI submitted comments to the OECD regarding its BEPS Project Pillar One and Pillar Two Blueprints. TEI’s comments focused on the specific questions posed by the OECD in its consultation document, including issues related to Amounts A and B under Pillar One, as well as the GloBE under Pillar Two.

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 Files Comments on Proposed Changes to Form 1065 Regarding International Items

On September 11, TEI submitted comments to the IRS regarding proposed changes to Form 1065 relating to international item reporting.

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 Files Comments regarding Proposed Regulations addressing the Foreign Tax Credit

On February 18, TEI submitted comments to the IRS and U.S. Treasury Department regarding proposed regulations related to the U.S. foreign tax credit. TEI’s comments primarily addressed the administrative burden the proposed regulations would impose on claiming a foreign tax credit due to a foreign tax redetermination under section 905(c), as well as issues related to “stewardship” expenses.

TEI Comments on the OECD’s “GloBE” Proposal

On December 2, TEI filed comments responding to the OECD’s public consultation document entitled Global Anti-Base Erosion Proposal (“GloBE”) – Pillar Two, focusing on the need for states to withdraw unilateral measures, a strong binding dispute resolution mechanism, and clear ordering rules, among other things.

TEI Files Comments regarding the OECD Secretariat’s “Unified Approach” to Pillar One

On November 11, TEI submitted comments to the OECD Secretariat regarding its proposed “unified approach” to “Pillar One” of the tax challenges of the digitalization of the economy. TEI’s comments focused on the need for (i) the withdrawal of unilateral measures after a multilateral agreement, (ii) a multilateral dispute resolution mechanism; and (iii) reliance on taxpayer consolidated financial statements for purposes of the approach, among other subjects.

TEI Files Comments on the Proposed GILTI High-Tax Exception

On September 18, TEI submitted comments to the Treasury and IRS regarding proposed regulations under section 951A, better known as “GILTI”, commending the Government on the proposed GILTI high-tax exception and recommending certain changes to the exception consistent with sound tax policy.

TEI Files Supplemental Comments on Proposed BEAT Regulations

Summary Sentence/Magazine Intro (1-2 sentences; abbreviate TEI; include committee and contributor recognition if needed): On August 12, TEI submitted comments to the Treasury and IRS regarding proposed regulations under section 59A, better known as the “BEAT”, recommending an alternative method to calculate a taxpayer’s BEAT liability.
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