The U.S. International Tax Committee works on educational and advocacy efforts regarding the U.S. taxation of international business operations.
On March 11, 2025, TEI filed comments with the IRS and U.S. Department of the Treasury regarding proposed regulations under section 987, which were published on December 11, 2024. TEI's comments…
On March 20, 2025, TEI submitted comments to an Expert-Sub Group of OECD Working Party 10 regarding the Working Party's GloBE Information Return XML Schema and User Guide, which was published on…
On March 2, 2025, TEI submitted comments regarding the long-awaited proposed previously taxed earnings and profits ("PTEP") regulations. TEI's comments focused on the need to eliminate double…
On December 17, 2024, TEI submitted comments to the OECD recommending it simplify the Pillar Two reporting requirements. TEI recommend the OECD help coordinate the timing of payments, adjustments,…
On October 7, 2024, TEI submitted comments to the Internal Revenue Service and U.S. Department of the Treasury regarding proposed regulations addressing dual consolidated losses ("DCL") and new…
On June 10, 2024, TEI sent a letter to the Brazilian tax authorities recommending Brazil adopt a cooperative compliance program with taxpayers. TEI noted the advantages of such a program include…
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…
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…
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…
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…
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,…
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…