U.S. International Tax Committee

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.

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.

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.

On May 6th, TEI submitted comments to the Internal Revenue Service and U.S. Department of the Treasury regarding proposed regulations on the new section 250 deductions for foreign-derived intangible income and global intangible low-taxed income.

On March 4th, TEI submitted comments to the OECD regarding its public consultation document entitled Addressing the Tax Challenges of the Digitalisation of the Economy. TEI will also participate in in the upcoming public consultation on March 13-14 in Paris.

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.

On February 19th, TEI submitted comments to the Treasury and IRS regarding proposed regulations providing guidance under section 59A regarding the base erosion and anti-abuse tax.

On February 5, 2019, TEI submitted responsive comments and recommendations to the Internal Revenue Service concerning the new proposed regulations under sections 861 and 904 of the Code (REG-105600-18). TEI’s comments, which are reprinted below, were developed by a cross-industry working group of Tax Reform Task Force and U.S. International Tax Committee members under the stewardship of TEI lawyers Watson M. McLeish and Benjamin R. Shreck.

On November 26th, TEI submitted comments to the Treasury and IRS regarding proposed regulations providing guidance under section 951A regarding global intangible low-taxed income.

On October 9th, TEI submitted comments to the Treasury and IRS regarding proposed regulations promulgated under the transition tax imposed by section 965, as amended by the Tax Cuts & Jobs Act enacted in 2017.