On April 28, 2023, TEI submitted comments to the Australian Treasury regarding the Treasury's proposal to require certain companies to publicly disclose tax information on a country-by-country ("CbC…
On May 31, 2023, TEI filed comments with the Canadian Department of Finance regarding a proposal to impose a penalty on taxpayers who violate Canada's general anti-avoidance rule ("GAAR"). TEI…
On March 30, 2023, TEI filed an amicus brief in Comcast v. Maryland, which is pending before the Maryland Supreme Court. The fundamental substantive issue in this case is whether the Maryland Digital…
On March 20, 2023, TEI submitted comments in response to a request for comments in Notice 2023-2, which provided guidance on the stock repurchase excise tax. The comments requested carve-outs from…
On March 20, 2023, TEI submitted a letter to the Internal Revenue Service commenting on Notice 2023-7, which provides initial guidance on the new corporate alternative minimum tax (CAMT) imposed by…
On February 23, 2023, TEI submitted comments to Canadian Finance Minister Chrystia Freeland regarding the proposed Canadian 2% tax on share buybacks. TEI took the view that Canada should not…
On February 13, 2023, TEI filed comments with the Canada Revenue Agency regarding Draft Form RC312 - Reportable Transaction and Notifiable Transaction Information Return. TEI's comments primarily…
On February 3, 2023, TEI provided comments to the Organisation for Economic Co-operation and Development ("OECD") regarding its public consultation on GloBE tax certainty under the OECD's two pillar…
On February 3, 2023, TEI submitted comments to the Organisation for Economic Co-operation and Development ("OECD") regarding the GloBE Information Return under Pillar Two of the OECD's project on the…
On January 31, 2023, TEI filed comments and recommendations with the Canadian Department of Finance regarding proposed excessive interest and financing expense limitation (EIFEL) legislation. The…
On January 25, 2023, TEI submitted comments to the Organisation for Economic Co-operation and Development ("OECD") regarding the OECD's public consultation on the design elements of Pillar One,…
On November 30, 2022, TEI submitted written comments to the U.S. Department of the Treasury and Internal Revenue Service requesting guidance on changes to section 174 under the Tax Cuts and Jobs Act…