Comment Letters

On March 21, 2016, TEI submitted comments to the IRS regarding proposed regulations (REG-109822-15) that would require certain U.S. headquartered multinational enterprises to report financial and tax information to the IRS on a country-by-country basis. The Institute's comments focused on the need for the final regulations to be consistent with the final report on Action 13 of the OECD's base erosion and profit shifting (BEPS) project to minimize the administrative burden on businesses and permit flexibility in information reporting.

On March 17, 2016, TEI submitted a letter to the Canada Revenue Agency recommending certain changes to paperwork requirements surrounding Regulation 102, specifically to Form RC473. The letter discusses concerns that taxpayers might have with completing that form, as well as other requirements that might be counterproductive toward encouraging taxpayer compliance with Regulation 102.

TEI's Canadian Income Tax Committee prepared this letter. Grant Lee chairs the Committee, and TEI Tax Counsel John Schoenecker coordinated the preparation of TEI's comments

On March 1, 2016, TEI submitted a letter to the Georgia Department of Revenue commenting on the Department's proposed amendments to Rule 560-12-1-.16, Georgia's "Direct Pay Reporting" regulation. TEI urged the Department to remove the provisions denying direct pay permit holders their statutory right to interest on refunds, as the proposed amendment conflicts with Georgia law and principles of sound tax policy.

On February 2, 2016, Tax Executives Institute submitted comments with HM Revenue & Customs, the revenue authority in the United Kingdom, regarding a proposal in the UK government's Finance Bill 2016 to require certain large businesses with UK operations to publish a UK tax strategy. The Institute's comments recommend clarifying the definition of a "UK sub-group" and how multinational businesses that are not headquartered in the United Kingdom can comply with the publication requirement.

On January 7, 2016, Tax Executives Institute filed comments with the European Commission regarding the Commission's "re-launch" of its common consolidated corporate tax base (CCCTB) proposal.

On January 5, 2016, TEI submitted a letter to Senator Braun and Representative Jinkins of the Washington Legislature urging the legislature to enact legislation establishing an independent tribunal to hear appeals of tax assessments and other matters administered by the Washington Department of Revenue.

On December 18, 2015, TEI submitted a letter to the Council of the European Union urging it to adopt revised rules setting out the value-added tax treatment for vouchers. The European Commission adopted a proposal to amend Directive 2006/112/EC, which addresses the common system of VAT in the European Union, as to the treatment of vouchers, in May 2012.

On December 18, 2015, TEI submitted a letter responding to the European Commission's Public Consultation on the modernization of VAT on cross border e-commerce transactions in the European Union. The Commission requested input from business and other interested parties to inform legislative proposals the Commission will draft to simplify value-added taxes on cross-border e-commerce transactions in the EU.

On October 12, 2015, TEI submitted a letter to the Canadian Department of Finance suggesting further legislative changes surrounding Regulation 102 in the form of (1) allowing self-certification as to “qualifying non-resident employer” status and (2) eliminating the $10,000 threshold for T4 reporting requirements. The proposed legislation would require employers to obtain advance certification from the CRA before being considered a “qualifying non-resident employer” as well as reporting on form T4 of all “qualifying non-resident employees” who make more than $10,000.

On October 14, 2015, Tax Executives Institute filed comments with HM Revenue & Customs, the revenue authority in the United Kingdom, regarding its consultation on Improving Large Business Tax Compliance. The Institute's comments focused on the Consultation's proposal to require large businesses to publish a tax strategy specific to their operations in the United Kingdom and the potential development of a Code of Practice on Taxation for Large Business, that could be voluntarily signed by interested taxpayers.