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.


Staff Liaison:

Ben Shreck, Tax Counsel


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

Foreign Tax Redeterminations under Section 905(c) - TEI Comments

On March 31, 2024, TEI submitted comments to the Internal Revenue Service (the "Service") regarding foreign tax redeterminations ("FTRs") under section 905(c). The post-TCJA final regulations resulted in a significant increase in the compliance burden on taxpayers with FTRs. TEI's letter recommended several methods to reduce this compliance burden as well as the administrative burden on the Service when auditing FTRs. TEI's comments were prepared under the aegis of its U.S. International Tax Committee, whose Chair is Ag Samoc. Benjamin R.

Notice 2023-80: DCLs and GloBE Interaction - TEI Comments

On February 9, 2024, TEI submitted comments to the Internal Revenue Service and U.S. Department of the Treasury regarding Notice 2023-80 (the "Notice"). The Notice provides interim guidance addressing the application of the foreign tax credit and dual consolidated loss ("DCL") rules to certain types of taxes described in the OECD Pillar Two Global Anti-Base Erosion ("GloBE") Model Rules.

Proposed Section 987 Regulations - TEI Comments

On February 12, 2024, TEI submitted comments regarding REG-132422-17 addressing recognition and deferral of section 987 gain or loss. TEI's comments included several simplifying recommendations to ease the compliance burden on taxpayers, a request to defer the effective date of any final regulations, and how to address suspended losses. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.

Read the comments here.

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 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 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.